Practice question
A treasurer rejects a timely letter solely because it lacks the caption Formal Protest. The letter clearly identifies the assessment, objects to the additional levy and explains the double-taxation ground. Which analysis follows China Banking?
- The absence of that caption alone does not invalidate the substantive written protest
- A particular caption is always indispensable
- No letter can ever qualify
- Only a new return can challenge an assessment
- The taxpayer must restate the same objection daily
Legal references
- China Banking v City Treasurer GR204117 July1,2015 MAIN: https://lawphil.net/judjuris/juri2015/jul2015/gr_204117_2015.html MAIN Protest validly filed.
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