Practice question
A taxpayer files its PAN reply late but later obtains a proper FAN reinvestigation, timely submits additional evidence and receives an FDDA discussing that evidence. It claims the late PAN reply necessarily means the evidence was never considered. Which Level Up principle is relevant?
- The actual later administrative evaluation must be examined; a late PAN reply does not erase demonstrated consideration during reinvestigation
- Every late PAN reply conclusively proves evidence was ignored forever
- An FDDA may never discuss additional evidence
- Reinvestigation evidence is legally invisible
- The taxpayer automatically wins whenever notices share wording
Legal references
- RR18-2013 Section3.1.4: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/10/67487 definition of relevant supporting documents.
- Level Up v CIR GR272354 September29,2025 MAIN: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/70267 MAIN administrative consideration of reinvestigation evidence.
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