Practice question
A party cites Nippon Express to deny all En Banc review of a final CTA Division local-tax decision even after the prescribed reconsideration step. Which correction is sound?
- The En Banc was abolished
- Every final tax appeal goes to the CA
- Every final decision is interlocutory
- Nippon concerns certiorari over Division interlocutory issuances, not abolition of ordinary En Banc appellate review
- No reconsideration requirement remains
Legal references
- CIR v. Nippon Express Philippines Corporation, G.R. No. 271701, May 6, 2025, en banc main decision: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/70179
- Revised Rules of the Court of Tax Appeals, AM 05-11-07-CTA, Rule 4: https://lawphil.net/courts/supreme/am/am_05_11_07_cta_2005.html
- City of Manila v. Cosmos Bottling Corporation, G.R. No. 196681, June 27, 2018, main decision: https://lawphil.net/judjuris/juri2018/jun2018/gr_196681_2018.html
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