CTA dismisses businesswoman’s appeal; protest submitted after 30-day prescriptive period

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The Court of Tax Appeals (CTA) has dismissed the petition of a Manila businesswoman to nullify the Bureau of Internal Revenue's (BIR) P4.8 million deficiency tax assessments for lack of authority to render judgment.

The Court of Tax Appeals has dismissed the petition of a Manila businesswoman to nullify the Bureau of Internal Revenue’s P4.8 million deficiency tax assessments for lack of authority to render judgment.In a 21-page resolution, the court’s Second Division stated that Jovita Panopio, proprietress of JG Panopio Designers and Builders of Tindalo Street, Tondo did not answer the assessments on time as prescribed under Section 228 of the Tax Code.

Ms. Panopio admitted during the trial that she received the assessment notices on Dec. 2, 2015 and submitted the protest on June 13, 2016, or 194 days later.The court also noted that the petitioner’s answer failed to state the facts, the applicable laws and regulations on which the protest was based.

 

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