Practice question
Excise tax due on specified excisable articles has not been paid. An auditor invokes Section228(d) solely to omit a PAN. What remains true?
- The PAN exception does not itself erase other applicable requirements for a valid assessment
- No written factual or legal basis can ever be required
- Every procedural safeguard disappears
- The taxpayer necessarily loses every protest remedy
- All taxes become immediately criminal fines
Legal references
- NIRC RA8424, Sections203,222–223 and228: https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html Section228(c)–(e), specific PAN exceptions.
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