Practice question
The BIR issues a FAN before the PAN response period expires, but delays delivery of the FAN until after the period and argues only delivery date matters. No exception applies. Which lesson follows Prime Steel?
- Delayed delivery always cures premature issuance
- The Court treated premature issuance itself as violating the protected PAN response opportunity
- A response to PAN is forbidden
- Only collection dates matter
- Every assessment must await a court trial
Legal references
- Prime Steel Mill, Inc. v. CIR, G.R. No. 249153, September 12, 2022, main decision: https://lawphil.net/judjuris/juri2022/sep2022/gr_249153_2022.html
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