Practice question
A company elects under Lascona to await the CIR's decision after the 180-day action period. It later validly receives the CIR's adverse final decision but lets the thirty-day appeal period expire, claiming the original waiting election permits it to wait indefinitely even after decision. What is correct?
- The waiting option does not eliminate the appeal deadline triggered by the eventual valid final decision
- The election permanently suspends every future deadline
- Only the company's preferred filing date matters
- The decision automatically becomes a refund certificate
- No court can review tax decisions
Legal references
- NIRC Sections204,228 and229: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/2/3896
- Lascona Land v. CIR, GR171251, March5 2012, main decision: https://lawphil.net/judjuris/juri2012/mar2012/gr_171251_2012.html
- RA9282 amending RA1125, CTA appeal provisions: https://lawphil.net/statutes/repacts/ra2004/ra_9282_2004.html
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