Practice question
A taxpayer expressly chooses to await resolution of a valid pending reinvestigation, objects promptly to a WDL, and later receives an explicit final denial. Explain why Mannasoft did not mechanically treat the WDL as the sole appeal trigger.
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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