Practice question
The BIR identifies a facial mathematical error within Section228's PAN exception. It argues that this also permits it to omit every written legal and factual basis for the resulting assessment. Which is correct?
- Correct; a PAN exception eliminates all assessment requirements.
- Correct; arithmetic cases never require notice of any kind.
- Correct; the taxpayer has no procedural rights.
- Incorrect; no mathematical-error PAN exception exists.
- Incorrect; the PAN exception does not erase the separate written-bases requirement.
Legal references
- NIRC Section228; https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html
- CIR v. Stradcom Corporation, G.R.255520, April21 2025, main decision (assessment and lawful collection); https://lawphil.net/judjuris/juri2025/apr2025/gr_255520_2025.html
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