Practice question
A taxpayer files a valid reinvestigation request and all relevant records on the same day. The BIR says those records do not count because they were not submitted later within the sixty days. What is correct?
- The taxpayer must wait until the last day
- The records automatically become irrelevant
- Only duplicates can support the claim
- No protest can include annexes
- Complete relevant annexes can constitute submission; a later artificial delivery is not invariably necessary
Legal references
- CIR v. First Express Pawnshop Company, Inc., G.R. Nos. 172045-46, June 16, 2009, main decision, relevant supporting documents: https://lawphil.net/judjuris/juri2009/jun2009/gr_172045_2009.html
- NIRC, Sections 6 and 228: https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html
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