Practice question
A taxpayer receives an actual full denial in 2026 of a refund application filed that year. It skips reconsideration and waits until day 25 to file directly with the CTA, invoking an older summary that says denial always starts a direct 30-day appeal. Assume no exceptional circumstance. Which current rule is decisive?
- A request for reconsideration was required within 15 days; failure renders the denial final under Section 112(C)
- The old summary overrides CREATE MORE
- Every filing within 90 days of denial is timely
- Reconsideration is prohibited in all VAT claims
- The refund is automatically approved because it was disputed
Legal references
- NIRC Section 112(C), as amended by RA 12066, Section 9: https://lawphil.net/statutes/repacts/ra2024/ra_12066_2024.html
- RR 8-2025 (claims filed on or after April 1, 2025): https://bir-cdn.bir.gov.ph/BIR/pdf/RR%208-2025.pdf
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