Sec.

203 - Period of Limitation Upon Assessment and Collection

SMI-ED Phil. Technology, Inc. v. Commissioner of Internal Revenue, G.R. No. 175410, November
12, 2014, citing Commissioner of Internal Revenue v. FMF Development Corporation, 579 Phil.
174 (2008)
Republic v. GMCC United Development Corp., G.R. No. 191856, December 7, 2016
Banco de Oro v. Republic, G.R. No. 198756, January 13, 2015
Republic v. GMCC United Development Corp., G.R. No. 191856, December 7, 2016
Commissioner of Internal Revenue v. Standard Chartered Bank, G.R. No. 192173, July 29, 2015
Commissioner of Internal Revenue v. Bank of the Philippine Islands, G.R. No. 135446,
September 23, 2003
Commissioner of Internal Revenue v. Pascor Realty and Devt. Corp., G.R. No. 128315, June 29,
1999
Commissioner of Internal Revenue v. GJM Philippines Manufacturing, Inc., G.R. No. 202695,
February 29, 2016
Commissioner of Internal Revenue v. Asalus Corp., G.R. No. 221590, February 22, 2017

Sec. 204 - Authority of the Commissioner to Compromise, Abate, and Refund or Credit Taxes

Commissioner of Internal Revenue v. Office of the Ombudsman, G.R. No. 115103, April 11, 2002
Chavez v. PCGG, G.R. No. 130716, December 9, 1998

Sec. 204 (B) - Abate or cancel a tax liability

Asiatrust Development Bank, Inc. v. Commissioner of Internal Revenue, G.R. Nos. 201530 &
201680-81, April 19, 2017

Sec. 204 (C) - Credit or refund taxes erroneously or illegally received or penalties imposed
without authority
Silkair (Singapore) Pte. Ltd. v. Commissioner of Internal Revenue, G.R. No. 184398, February 25,
2010
Commissioner of Internal Revenue v. Petron Corp., G.R. No. 185568, March 21, 2012

Chapter II - Civil Remedies for Collection of Taxes

Sec. 205 - Remedies for the Collection of Delinquent Taxes
Ungab v. Cusi, Jr., G.R. Nos. L-41919-24, May 30, 1980

Sec. 206 - Constructive Distraint of the Property of a Taxpayer

Azarcon v. Sandiganbayan, G.R. No. 116033, February 26, 1997

Sec. 207 (A) and (B) - Distraint and Levy

David v. Ramos, G.R. No. L-4300, October 31, 1951

Sec. 209 - Sale of Property Distrained and Disposition of Proceeds

Azarcon v. Sandiganbayan, G.R. No. 116033, February 26, 1997

Sec. 218 - Injunction not Available to Restrain Collection of Tax

Churchill v. Rafferty, G.R. No. 10572, December 21, 1915
David v. Ramos, G.R. No. L-4300, October 31, 1951
Commissioner of Internal Revenue v. Cebu Portland Cement Co., G.R. No. L-29059, December
15, 1987
Spouses Pacquiao v. Court of Tax Appeals, G.R. No. 213394, April 6, 2016

Sec. 219 - Nature and Extent of Tax Lien

Republic v. Enriquez, G.R. No. 78391, October 21, 1988

Sec. 220 - Form and Mode of Proceeding in Actions Arising under NIRC
Commissioner of Internal Revenue v. La Suerte Cigar and Cigarette Factory, G.R. No. 144942,
June 28, 2001
LG Electronics Phils., Inc. v. Commissioner of Internal Revenue, G.R. No. 165451, December 3,
2014
People v. Valeriano, G.R. No. 199480, October 12, 2016

Sec. 221 - Remedy for Enforcement of Statutory Penal Provisions

Proton Pilipinas Corp. v. Republic, G.R. No. 165027, October 16, 2006

Sec. 222 - Exceptions as to Period of Limitation of Assessment and Collection of Taxes

Adamson v. Court of Appeals, G.R. Nos. 120935 & 124557, May 21, 2009
Commissioner of Internal Revenue v. Estate of Toda, Jr., G.R. No. 147188, September 14, 2004
Commissioner of Internal Revenue v. Wyeth Suaco Laboratories, Inc., G.R. No. 76281,
September 30, 1991
Commissioner of Internal Revenue v. Pascor Realty and Devt. Corp., G.R. No. 128315, June 29,
1999
Commr. v. Stanley Works Sales (Phils.), Inc., G.R. No. 187589, December 3, 2014, citing Republic
v. Ablaza, G.R. No. L-14519, July 26, 1960

Sec. 222 (a) - Exceptions as to Period of Limitation of Assessment and Collection of Taxes
Samar-I Electric Cooperative v. Commissioner of Internal Revenue, G.R. No. 193100, December
10, 2014, citing Aznar v. Court of Tax Appeals, 157 Phil. 510 (1974)
Republic v. GMCC United Development Corp., G.R. No. 191856, December 7, 2016
Commissioner of Internal Revenue v. Philippine Daily Inquirer, Inc., G.R. No. 213943, March 22,
2017

Sec. 222 (b) - Exceptions as to Period of Limitation of Assessment and Collection of Taxes
Commissioner of Internal Revenue v. Kudos Metal Corp., G.R. No. 178087, May 5, 2010

Sec. 222 (e) - Exceptions as to Period of Limitation of Assessment and Collection of Taxes
ING Bank N.V. v. Commissioner of Internal Revenue, G.R. No. 167679, July 22, 2015
Commissioner of Internal Revenue v. Philippine Aluminum Wheels, Inc., G.R. No. 216161,
August 9, 2017

Sec. 223 - Suspension of Running of Statute of Limitations

Commissioner of Internal Revenue v. Hambrecht & Quist Philippines, Inc., G.R. No. 169225,
November 17, 2010
Bank of the Philippine Islands v. Commissioner of Internal Revenue, G.R. No. 174942, March 7,
2008

Chapter III - Protesting an Assessment, Refund, Etc.

Sec. 228 - Protesting of Assessment
Allied Banking Corp. v. Commissioner of Internal Revenue, G.R. No. 175097, February 5, 2010
Fishwealth Canning Corp. v. Commissioner of Internal Revenue, G.R. No. 179343, January 21,
2010
Commissioner of Internal Revenue v. Enron Subic Power Corp., G.R. No. 166387, January 19,
2009
University Physicians Services, Inc. v. Commissioner of Internal Revenue, G.R. No. 205955,
March 7, 2018
Commissioner of Internal Revenue v. Isabela Cultural Corp., G.R. No. 135210, July 11, 2001
Commissioner of Internal Revenue v. Bank of the Philippine Islands, G.R. No. 134062, April 17,
2007
Commissioner of Internal Revenue v. Phil. Global Communication, Inc., G.R. No. 167146,
October 31, 2006
Lascona Land Co., Inc. v. Commissioner of Internal Revenue, G.R. No. 171251, March 5, 2012
citing RCBC v. CIR, G.R. No. 168498, April 24, 2007
Commissioner of Internal Revenue v. Liquigaz Philippines Corp., G.R. Nos. 215534 & 215557,
April 18, 2016
Commissioner of Internal Revenue v. Liquigaz Philippines Corp., G.R. Nos. 215534 & 215557,
April 18, 2016

Sec. 229 - Recovery of Tax Erroneously or Illegally Collected

Commissioner of Internal Revenue v. Far East Bank & Trust Co., G.R. No. 173854, March 15,
2010
Commissioner of Internal Revenue v. Primetown Property Group, Inc., G.R. No. 162155, August
28, 2007
BPI Leasing Corp. v. Court of Appeals, G.R. No. 127624, November 18, 2003
SMI-ED Phil. Technology, Inc. v. Commissioner of Internal Revenue, G.R. No. 175410, November
12, 2014
Philippine National Bank v. Commissioner of Internal Revenue, G.R. No. 206019, March 18,
2015
Commissioner of Internal Revenue v. Philippine American Life Insurance Co., G.R. No. 105208,
May 29, 1995
Title IX - Compliance Requirements
Chapter II - Administrative Provisions
Sec. 237 - Issuance of Receipts or Sales or Commercial Invoices
Southern Phil. Power Corp. v. Commissioner of Internal Revenue, G.R. No. 179632, October 19,
2011
Panasonic Communications Imaging Corp. of the Phil. v. Commissioner of Internal Revenue,
G.R. No. 178090, February 8, 2010

Chapter III - Rules and Regulations

Sec. 244 - Authority of the Secretary of Finance to Promulgate Rules and Regulations
Compania General de Tabacos de Filipinas v. Court of Appeals, G.R. No. 147361, March 23, 2004
Commissioner of Internal Revenue v. Michel J. Lhuillier Pawnshop, Inc., G.R. No. 150947, July
15, 2003
Chamber of Real Estate and Builders' Associations, Inc. v. Romulo, G.R. No. 160756, March 9,
2010

Sec. 246 - Non-Retroactivity of Rulings

Supreme Transliner, Inc. v. BPI Family Savings Bank, Inc., G.R. Nos. 165617 & 165837, February
23, 2011
Commissioner of Internal Revenue v. San Roque Power Corp., G.R. Nos. 187485, 196113 &
197156, October 8, 2013
Commissioner of Internal Revenue v. Puregold Duty Free, Inc., G.R. No. 202789, June 22, 2015,
citing Serrano de Agbayani v. Philippine National Bank, 148 Phil. 443, 447-448 (1971)

Sec. 248 (A) - Civil Penalties

Commissioner of Internal Revenue v. St. Luke's Medical Center, Inc., G.R. No. 203514, February
13, 2017

Sec. 248 (B) - Willful Neglect to File Returns or Filing of False or Fraudulent Returns
Aznar v. Court of Tax Appeals, G.R. No. L-20569, August 23, 1974

Sec. 249 - Interest

Aguinaldo Industries Corp. (Fishing Nets Division) v. Commissioner of Internal Revenue, G.R. No.
L-29790, February 25, 1982

Sec. 251 - Failure of a Withholding Agent to Collect and Remit Tax

National Development Company v. Commissioner of Internal Revenue, G.R. No. L-53961, June
30, 1987

Title X - Statutory Offenses and Penalties

Chapter II - Crimes, Other Offenses and Forfeitures
Sec. 253 - Crimes, Other Offenses and Forfeitures: General Provisions
Ungab v. Cusi, Jr., G.R. Nos. L-41919-24, May 30, 1980

Sec. 254 - Attempt to Evade or Defeat Tax

Commissioner of Internal Revenue v. Court of Appeals, G.R. No. 119322, June 4, 1996
Gaw, Jr. v. Commissioner of Internal Revenue, G.R. No. 222837, July 23, 2018

Sec. 255 - Failure to File Return, Supply Correct and Accurate Information, Pay Tax, Withhold
and Remit Tax and Refund Excess Taxes Withheld on Compensation
Commissioner of Internal Revenue v. Estate of Toda, Jr., G.R. No. 147188, September 14, 2004
Bureau of Internal Revenue v. Court of Appeals, G.R. No. 197590, November 24, 2014, citing
Commissioner of Internal Revenue v. Court of Appeals, 327 Phil. 1 (1996)
CS Garment, Inc. v. Commissioner of Internal Revenue, G.R. No. 182399, March 12, 2014

Sec. 267 - Declaration under Penalties of Perjury

Commissioner of Internal Revenue v. Philippine National Bank, G.R. No. 180290, September 29,
2014

Sec. 270 - Unlawful Divulgence of Information

Dipad v. Spouses Olivan, G.R. No. 168771, July 25, 2012

Sec. 272 - Violation of Withholding Tax Provision

Bureau of Internal Revenue v. Organo, G.R. No. 149549, February 26, 2004

Sec. 282 - Informer's Reward

Commissioner of Internal Revenue v. Commission on Audit, G.R. No. 101976, January 29, 1993
Meralco Securities Corp. v. Savellano, G.R. No. L-36181, October 23, 1982