Practice question
Distinguish the thirty-day protest deadline, the reinvestigation evidence period and the substance of a request labeled reconsideration but relying on new records.
Legal references
- NIRC, Sections 6 and 228: https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html
- 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
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