Practice question
A taxpayer timely files a fully documented 2026 ordinary Section 204(C) claim within two years of payment. The CIR issues a partial denial on day 100. The taxpayer insists it must wait until day 180 before appealing the denied portion. No special exception applies. Which is correct?
- It must always ignore an actual denial until day 180.
- The partial denial triggers the statutory 30-day appeal period from receipt; it should not be treated as mere continuing inaction.
- The taxpayer has a fresh two years after denial to appeal.
- A partial denial eliminates CTA jurisdiction forever.
- The administrative claim must be withdrawn before any appeal.
Legal references
- NIRC Sections204(C) and229, as amended by RA11976 Sections31–32; https://lawphil.net/statutes/repacts/ra2024/ra_11976_2024.html
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