Practice question
A taxpayer timely elevates a representative’s denial but labels the filing an administrative reinvestigation seeking entirely new evidence. It insists this remedy is unconditionally available. Which is correct?
- RR18-2013 permits administrative reconsideration but disallows reinvestigation at that appeal stage
- Every original-protest remedy repeats without restriction at every stage
- New evidence automatically guarantees a new administrative audit
- Only the filing caption can override the regulation
- The taxpayer can privately repeal the restriction
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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