Practice question
A valid reinvestigation remains unresolved after180 days. The taxpayer promptly objects to a WDL and expressly elects to await the decision. The BIR later sends a letter explicitly denying the protest as its final decision, and CTA review is timely measured from that letter. The BIR invokes old cases treating every WDL as the mandatory appeal trigger. Which is closest to Mannasoft?
- The Court recognized the waiting election and treated the later express final denial as appealable on the stated facts
- Every WDL invariably destroys the waiting option
- A valid pending reinvestigation can never matter
- The taxpayer must always file a new protest instead of judicial review
- A WDL automatically validates every assessment defect
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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