Practice question
Discuss BPI's exceptional estoppel analysis without treating every protest as an unlimited collection extension.
Legal references
- NIRC Sections204,206-208,222-223 and248-249, as applicable and amended: https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html
- BPI v. CIR, G.R.139736, October17,2005, MAIN decision: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/41647
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