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Essay Multiple Choice

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All Jurisprudence based

0 tracked cards Commercial and Taxation Laws

The taxpayer establishes that a purported deficiency assessment entirely omitted the written factual and legal bases required by Section 228. The BIR answers solely that the taxpayer did not protest it, so the defect is cured by finality. Which analysis is correct?

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No procedural requirement can ever invalidate a tax assessment The BIR must still satisfy the threshold validity requirement; failure to protest is not a substitute for the mandatory written bases The defect automatically exempts the taxpayer from every future tax Every void assessment becomes valid through silence

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