Practice question
Can relevant documents submitted with a valid protest already satisfy submission, if they are complete for the stated grounds?
- Never, they must always be withheld until day 60
- Only if submitted twice
- Yes; First Express recognized documents attached to the protest rather than requiring a later artificial filing
- Only after a collection warrant
- Only after the taxpayer loses in court
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
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