Practice question
A true mathematical-error case satisfies a statutory PAN exception. The BIR argues that this also excuses it from informing the taxpayer in writing of every legal and factual basis of the assessment. Which assessment is sound?
- Every PAN exception abolishes all due process
- The taxpayer automatically loses all protest rights
- The tax becomes a private debt
- A PAN exception does not by itself erase Section 228’s written-basis requirement for the assessment
- Any assessment is valid if the tax amount is large
Legal references
- NIRC Sections6,13 and228: https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html
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