Practice question
A company refuses a due tax payment while its refund claim is unresolved. The refund is later partly granted. It argues that later success necessarily made the earlier nonpayment timely and removed every delinquency consequence. What follows from Philex?
- Later partial success always validates every earlier refusal
- The later credit does not automatically excuse the earlier unauthorized nonpayment or erase applicable delinquency consequences
- Refund claims can never succeed
- The tax authority may keep every lawful credit unused
- All refund rules are abolished
Legal references
- Philex Mining Corporation v. CIR, G.R. No. 125704, August 28, 1998, main decision: https://lawphil.net/judjuris/juri1998/aug1998/gr_125704_1998.html
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