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Due Process in Tax Assessments: Strict Adherence to Notice Requirements
The Supreme Court nullified a deficiency tax assessment because the BIR issued the Final Assessment Notice before the taxpayer's 15-day period to reply to the Preliminary Assessment Notice lapsed.
Dec 8, 2010tax lawdue processpreliminary assessment noticebirdeficiency assessmentadministrative law
Due Process in Philippine Tax Assessments: The Critical Role of the Preliminary Assessment Notice
Philippine tax assessments require a Preliminary Assessment Notice; without it, the assessment is void for denying due process.