Practice question
The CIR’s duly authorized representative denies a protest. Within thirty days of receipt, the taxpayer seeks reconsideration by the CIR rather than immediately appealing to the CTA. Assuming compliance with the regulation, is that administrative route categorically unavailable?
- No, RR 18-2013 recognizes elevation by reconsideration to the CIR as an alternative to the timely CTA appeal from the representative’s denial
- Yes, only a criminal complaint is possible
- Yes, the representative’s decision can never be reviewed
- Yes, but the taxpayer may instead demand a new reinvestigation in that administrative appeal
- Yes, every denial must be appealed directly to the Supreme Court
Legal references
- https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html — NIRC, section 228
- https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/10/67487 — RR 18-2013, section 3.1.4, disputed assessments
- https://lawphil.net/judjuris/juri2012/mar2012/gr_171251_2012.html — Lascona Land Co., Inc. v. CIR, G.R. No. 171251, March 5, 2012
- https://lawphil.net/judjuris/juri2023/jul2023/gr_244202_2023.html — Mannasoft Technology Corporation v. CIR, G.R. No. 244202, July 10, 2023
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