Practice question
A valid protest seeks reconsideration solely on existing records. The BIR says it automatically fails because no newly discovered evidence was filed during an extra sixty days. Which is correct?
- Every reconsideration requires newly discovered evidence
- Only a PAN response may use existing records
- Reconsideration cannot involve legal arguments
- The taxpayer must request reinvestigation in every case
- The sixty-day additional-document period does not apply to reconsideration as such
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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