Practice question
A company timely requests reinvestigation, identifies invoices as additional evidence, but submits none of the relevant supporting records within sixty days. It later insists on introducing them as of right in that administrative reinvestigation. What consequence does RR 18-2013 prescribe?
- The taxpayer is barred from disputing correctness by newly discovered or additional evidence, and the protest is consequently denied
- The BIR must allow unlimited late submissions
- The tax is automatically cancelled
- The failure converts the case into an RPT appeal
- The original thirty-day protest deadline is automatically extended forever
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
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