Practice question
All relevant supporting documents are established submitted with the protest. The BIR demands extraneous papers and claims that merely repeating requests can postpone the statutory action period indefinitely. Which lesson follows First Express?
- Any repeated request automatically restarts every period
- The statutory period cannot be made indefinitely dependent on arbitrary document demands; actual relevant submission must be identified
- The taxpayer has no judicial remedy
- Only the auditor chooses whether time exists
- Every supporting document guarantees cancellation
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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