Practice question
A business pays a validly assessed local tax after timely protest and then timely requests refund on the same grounds. The treasurer denies its protest. It plans to sue eighteen months later, reasoning that any suit labeled refund has two years. Which analysis follows Cosmos?
- The refund label conclusively removes the assessment from the dispute
- The action remains tied to the protested assessment and must observe the thirty-day judicial deadline, not merely the two-year outer refund period
- Payment makes every assessment challenge impossible
- No administrative filing was needed under either section
- The dispute automatically becomes a national income-tax case
Legal references
- RA7160, Section196: https://lawphil.net/statutes/repacts/ra1991/ra_7160_1991.html
- RA7160, Section195: https://lawphil.net/statutes/repacts/ra1991/ra_7160_1991.html
- City of Manila v. Cosmos Bottling, G.R.196681, June27 2018: https://lawphil.net/judjuris/juri2018/jun2018/gr_196681_2018.html
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