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2026.01.07 22:20
Once an evaluation is made or slots free issued, the taxpayer can't choose to pay the assessment and thereafter seek a refund at any time inside the complete interval of two (2) years from the date of cost as Section 196 of LGC of 1991, as amended, Best online Slots could counsel. The Court dominated that Section 195 of the LGC of 1991, as amended, requiring the filing of a protest would nonetheless apply even when the taxpayer opts to pay the quantity assessed inside the identical interval of 60 days and subsequently claims for free slots online refund beneath Section 196 of the same legislation.
Here, because the Billing Assessment Forms had been issued to the taxpayer and they qualify as the notices of assessment contemplated by regulation, it could not comply with Section 196 of the LGC of 1991, free online slots as amended, with out complying with the requirement of filing a protest under Section 195 of the identical regulation. Quite the opposite, Section 196 of the LGC of 1991, Casino slots as amended, would apply, without requiring prior compliance with Section 195, if no discover of evaluation was issued to the taxpayer.
In ruling towards the CIR, the Court held that the term "related supporting paperwork" for purposes of the above-quoted Section 228 of the 1997 NIRC, as amended, refers back to the paperwork essential to assist the legal basis in disputing a tax assessment, as decided by the concerned taxpayer and never by the BIR. The latter can only inform the former to submit further paperwork, but the BIR can not demand what type of supporting paperwork must be submitted.
To rule in any other case would, in impact, place the taxpayer on the mercy of the BIR, which may require the manufacturing of documents which said taxpayer could not be capable to submit. In the identical vein, it's not appropriate for the taxpayer to recognize mentioned erroneously handed-on VAT as input taxes. Consequently, this failure on the part of the taxpayer should result within the denial of its declare for input VAT refund. The Commission cannot tolerate and Casino slots ignore any act or omission on the a part of those involved in the capital market which would violate the norm set by the securities legislation particularly on the transactions and obligations of Broker Dealers and that might diminish or even simply are inclined to diminish the religion of the investors on the integrity of the capital market.