Practice question
The BIR extrapolates an entire year's receipts from a brief surveillance period. The taxpayer produces reliable records showing peak and off-peak seasons and material price changes that undermine the assumption of constant sales. The BIR says Section 6(C) makes every surveillance estimate conclusive. Which response is correct?
- All surveillance is illegal
- The statute eliminates the taxpayer's right to contrary evidence
- The estimate and its assumptions must be evaluated; statutory use of surveillance does not make an unsupported projection conclusive
- Every taxpayer estimate is automatically correct
- Only the number of pages in the report matters
Legal references
- NIRC Sections5–6,13 and228: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/2/3896
- CIR v. Hantex Trading, GR136975, March31 2005, main decision: https://lawphil.net/judjuris/juri2005/mar2005/gr_136975_2005.html
- CIR v. Spouses Magaan, GR232663, May3 2021, main decision: https://lawphil.net/judjuris/juri2021/may2021/gr_232663_2021.html
- CIR v. Elric Auxiliary Services, GR226945, February19 2026, main decision: https://lawphil.net/judjuris/juri2026/feb2026/gr_226945_2026.html
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