Practice question
An audit discrepancy is proven to be an inadvertent encoding mistake, without deliberate falsity or intent to evade. No unrebutted statutory presumption, nonfiling, waiver or suspension applies. The CIR invokes ten years solely because the return was inaccurate. Under Villanueva, which conclusion follows?
- Inaccuracy alone does not establish the extraordinary ground; the ordinary period governs on these facts
- Every discrepancy automatically triggers ten years
- A taxpayer may never explain an error
- The examiner may choose either period without grounds
- An inaccurate filed return is automatically nonexistent
Legal references
- CIR v. Villanueva, G.R. 249540, February 28, 2024, main decision: https://lawphil.net/judjuris/juri2024/feb2024/gr_249540_2024.html
Answer this question in flashcards to review your response and continue practicing.