Practice question
A taxpayer disputes alleged unreported sales using reconciliations and invoices in a timely PAN response. The BIR ignores the submissions without explanation and reproduces the same conclusions in its final demand. Which principle from Avon applies?
- Receiving papers alone always satisfies due process
- The BIR must accept every taxpayer assertion as true
- The BIR may destroy contrary evidence
- A genuine opportunity to be heard includes reasoned consideration of the taxpayer’s evidence, though acceptance is not compulsory
- The PAN response automatically cancels the proposed tax
Legal references
- https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html — NIRC, section 228
- https://lawphil.net/judjuris/juri2022/sep2022/gr_249153_2022.html — Prime Steel Mill, Inc. v. CIR, G.R. No. 249153, September 12, 2022
- https://lawphil.net/judjuris/juri2018/oct2018/gr_201398-99_2018.html — CIR v. Avon Products Manufacturing, Inc., G.R. Nos. 201398-99 and 201418-19, October 3, 2018
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