Practice question
The BIR issues the FAN seven days after the taxpayer receives the PAN, before the fifteen-day response period expires. No exception or waiver applies. Does later opportunity to protest automatically cure the premature issuance?
- Yes, every later protest cures it
- Yes, the PAN response period is optional
- Only the tax amount matters
- No; Prime Steel rejected that substantial-compliance argument
- Only the invoice format matters
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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