Practice question
In a closure-related dispute, an officer extrapolates one peak sales sample across all quarters while ignoring supported seasonal and price changes. It claims Elric makes every surveillance estimate automatically conclusive. Which is best?
- Every estimate is irrebuttable by definition.
- Surveillance-based estimates remain subject to reasonableness and scrutiny of their factual basis.
- Elric prohibits all surveillance for every purpose.
- Only the officer's preferred revenue target supplies a factual basis.
- The taxpayer must disprove figures whose methodology is never disclosed.
Legal references
- NIRC Sections208-210,215-219: https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html
- RA12023 Section9, amended NIRC115: https://lawphil.net/statutes/repacts/ra2024/ra_12023_2024.html
- CIR v. Elric Auxiliary Services Corporation, G.R.226945, February19,2026, MAIN decision: https://lawphil.net/judjuris/juri2026/feb2026/gr_226945_2026.html
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