Practice question
A protest is captioned reconsideration but expressly seeks re-evaluation on newly discovered invoices not in the existing record. Which approach best applies the functional distinction discussed in Citysuper?
- The caption conclusively prevents reinvestigation treatment
- No supporting records may ever matter
- Every protest is identical
- Assess the actual request for additional evidence and its reinvestigation requirements, rather than the label alone
- The taxpayer automatically wins
Legal references
- CIR v. CTA Third Division and Citysuper, Inc., G.R. No. 239464, May 10, 2021, main decision: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/67428
Answer this question in flashcards to review your response and continue practicing.