Practice question
A closure-related VAT notice states only that surveillance proves a deficiency. It omits how surveillance was conducted and how the sales estimates were derived. The taxpayer cannot meaningfully test the figures. The BIR argues that every surveillance estimate is immune from review. Which analysis follows Elric Auxiliary?
- Every estimate is automatically conclusive
- Surveillance can never be used for any lawful purpose
- A total alone always supplies the factual basis
- A taxpayer has no right to understand the claim
- The basis and reasonable method must be disclosed; arbitrary unsupported estimates do not satisfy the required factual foundation
Legal references
- CIR v. Elric Auxiliary Services/Sacred Heart Gas Station, G.R. 226945, February 19, 2026: https://lawphil.net/judjuris/juri2026/feb2026/gr_226945_2026.html
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