Practice question
A final ordinary assessment remains unpaid, but the BIR first commences qualifying collection more than three years after mailing it. No suspension, waiver, extension or extraordinary ground exists. Explain why finality does not settle the prescription issue in the government's favor.
Legal references
- CIR v. CTA Second Division and QL Development, Inc., G.R.258947, March29 2022, main decision; https://lawphil.net/judjuris/juri2022/mar2022/gr_258947_2022.html
- NIRC Sections203 and222(c); https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html
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