Practice question
In a 2026 ordinary non-VAT refund claim governed by Sections 204(C) and 229, complete documents were submitted 60 days ago. The CIR has issued no full or partial denial. No special rule or exception applies. The taxpayer files a judicial refund claim immediately, arguing that an administrative filing alone always permits immediate suit. Which is correct?
- The claim is premature under the stated framework because neither denial nor expiry of the 180-day period has occurred.
- Every administrative filing necessarily permits immediate judicial suit.
- The 180-day period is irrelevant for all 2026 claims.
- The taxpayer must wait five years in every case.
- The claim is automatically approved because 60 days passed.
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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