Practice question
A company timely responds to a PAN with records. Later it validly receives the FAN but files no request contesting that formal assessment within thirty days, assuming the earlier reply automatically carries forward as its FAN protest. No unusual facts or exception applies. Which analysis is correct?
- Every PAN reply automatically constitutes every future protest
- The formal assessment requires its own timely valid protest; the prior preliminary response does not automatically satisfy that requirement
- The FAN period runs only after the company chooses to open another envelope
- The PAN reply abolishes all assessment procedures
- Only the company's annual return is required
Legal references
- NIRC Sections5–6,13 and228: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/2/3896
- CIR v. CTA Third Division and Citysuper, GR239464, May10 2021, main decision: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/67428
- CIR v. Elric Auxiliary Services, GR226945, February19 2026, main decision: https://lawphil.net/judjuris/juri2026/feb2026/gr_226945_2026.html
- Level Up v. CIR, GR272354, September29 2025, main decision: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/70267
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