Practice question
A representative denies a protest on three identified issues. The taxpayer timely elevates reconsideration to the CIR but adds a wholly unrelated issue never raised in the decision. What restriction applies?
- The administrative appeal is confined to issues raised in the representative’s decision
- Timeliness alone expands the appeal to every issue
- The CIR must decide all future tax years too
- Every added issue automatically cancels the denial
- There are no subject-matter limits
Legal references
- RR18-2013 Section3.1.4: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/10/67487 administrative appeal limits and mutually exclusive remedies.
- Mannasoft v CIR GR244202 July10,2023 MAIN: https://lawphil.net/judjuris/juri2023/jul2023/gr_244202_2023.html MAIN warrant and election to await final decision.
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