TAX REMEDIES
Tax Remedies speak of three (3) kinds, namely:
1. Remedies in General
2. Remedies of the government; and
3. Remedies of the Taxpayer.
I. REMEDIES IN GENERAL
The COMMISSIONER has the power to:
1. COMPROMISE payment of ANY
Internal Revenue Tax.
(A compromise is an agreement
whereby the parties, by making
reciprocal concessions, avoid
litigation or put an end to one
already commenced (ART. 2208,
CIVIL CODE)
2. ABATE or CANCEL a Tax Liability
(Abatement is a diminution or
decrease in the amount of tax
imposed. To abate is to nullify or
reduce in value or amount; while to
When:
1. A Reasonable Doubt as to the validity of
the claim against the Taxpayer.
2. Inability of the Taxpayer to pay assessed
tax.
The Compromise settlement of any tax liability
shall be subject to the following minimum
amounts:
a. For cases of financial incapacity, a
minimum compromise of 10% of the basic
assessed tax; and
b. For other cases, minimum compromise
rate is 40% of the basic assessed tax.
When:
1. The tax or portion thereof appears to be
unjustly or excessively assessed;
2. The administration and collection costs
involved do not justify collection of the
Recommendation/Final Report on the
application for Compromise shall be
signed/approved by:
1. Concerned Regional Evaluation
Board (REB).
a. Regional Office cases involving
basic tax assessment of P500,000
or less;
b. Minor criminal violations discovered
by regional and district already
delegated to REB.
2. CIR
a. Other cases w/c were not delegated
b. Cases which, by law, have been
entrusted to the CIR
3. National Evaluation Board
a. Basic Tax exceeds P1,000,000
b. Where settlement offered is less
than the prescribed minimum
compromise settlement amount
(10% for cases of financial
incapacity and 40% for cases of
doubtful validity of the assessment.
The RDO/investigating offices having
jurisdiction over the taxpayer-applicant
shall:
1. Process the application for
Abatement.
2. Make necessary evaluation
cancel is to obliterate, cross-out, or
invalidate.)
Under the existing rules, the BIR
processes applications for the
abatement of ONLY:
a. Surcharges
b. Interests
c. Compromise Penalties
(Any application for the abatement of
the basic tax assessed or any portion
thereof if any, is not covered by
existing rules and therefore shall not
be processed)
3. CREDIT or REFUND:
(Tax Credit is not specifically defined in
our Tax Code, but Art. 21 of EO 226
defines a tax credit as any of the
credits against taxes and or duties
equal to those actually paid or would
have been paid to evidence which a
Tax Credit Certificate (TCC) shall be
issued by the SECRETARY OF
FINANCE or his representative, or the
Board of Investments, is so delegated
by the Secretary of Finance.)
In RR 5-2000, a tax credit is defined
as the amount due to a taxpayer
resulting from an overpayment of a tax
liability or erroneous payment of a tax
due.
amount due.
All criminal violations may be compromised
EXCEPT:
a. Those already filed in court
b. Those involving Fraud
1. Taxes erroneously or illegally received.
2. Penalties imposed without authority.
A Tax Credit Certificate (TCC) validly issued may
be applied against any internal revenue tax,
EXCEPT Withholding taxes, for which the
taxpayer is directly liable.
A. Forfeiture of Refund
A refund check or warrant issued which shall
remain unclaimed or uncashed within five (5)
years from the date of the said warrant or
check was mailed or delivered shall be
forfeited in favour of the Government and the
amount thereof shall revert to the general
fund.
B. Forfeiture of Tax Credit
A Tax Credit Certificate issued which shall
remain unutilized after five (5) years from the
date of issue, shall, unless revalidated, be
considered invalid, and shall not be allowed
as payment for internal revenue tax liabilities
of the taxpayer, and the amount covered by
the certificate shall revert to the general fund.
3. Prepare report containing
recommendation to the Technical
Working Committee (TWC.)
The TWC shall:
1. Review the report and
recommendation.
2. Prepare the final recommendation
for the approval of the
Commissioner.
The Commissioner shall approve the
application.
Requirements for Refund:
(CIR vs. Acosta)
1. A written claim for refund or tax credit
must be filed by the taxpayer with the
commissioner
2. The claim for refund must be a
categorical demand for
reimbursement
3. The claim for refund or tax credit must
be filed, or the suit or proceeding
therefor must be commenced in court
within two (2) years from date of
payment of the tax or penalty
regardless of any supervening cause.
Goodwill and Patriotism Doctrine:
In CIR v. PNB. An exception to the 2-yr
period was laid down by the high court.
PNB remitted the P180 Million in question
as a measure of goodwill and patriotism to
help the cash-strapped national
government; It would thus be unfair to leave
respondent PNB to suffer losing millions of
pesos advanced by it for future tax
liabilities.
II. REMEDIES OF THE GOVERNMENT
1. ASSESSMENT Time of Assessment
An assessment contains: a. 3-year Period (General Rule)
a. Computation of tax liabilities 1. If the return was filed on or before the deadline for filing – within 3
b. A demand for payment within the prescribed years after the last prescribed by law
period. 2. If the return was filed beyond or after the deadline – within 3 years
from the date of such filing.
- It signals the time when penalties and interests begin b. 10-year period (Exception)
to accrue against. 1. For false or fraudulent return with intent to evade tax or failure to file a
- It must be served on and received by the taxpayer. return – at any time within ten (10) years after discovery of the falsity,
- An assessment is deemed made only when the fraud, or omission.
collector of internal revenue releases, mails or send
such notice to the taxpayer.

2. COLLECTION Administrative Procedure:

A. Collection with Assessment: (Gen. Rule)
Any internal revenue taxes which has been
assessed may be collected within five (5) years
following the assessment of the tax by:
1. Distraint
2. Levy
3. Judicial Action
a. Civil
b. Criminal
B. Collection w/out assessment: (Exception)
In the case of a false or fraudulent return with
intent to evade tax or failure to file a return, the tax
may be assessed, OR a proceeding in court after
the collection of such tax may be begun WITHOUT
assessment, at any time within ten (10) years
after the discovery of the falsity, fraud or
omission. Provided, that in fraud assessment
which has become final and executor, the fact of
fraud shall be judicially taken cognizance of in the
civil or criminal action for collection thereof.
In Section 205 of the Code, it
provides:
Remedies for the collection of
Delinquent Taxes. –
The civil remedies for the
collection of internal revenue
taxes, fees or charges, and any
increment thereto resulting from
delinquency shall be:
1. By DISTRAINT of goods,
chattels, or effects, and
other Personal property of
whatever character,
including stocks and other
securities, debts, credits,
bank accounts and interest
in and rights to personal
property.
2. By LEVY upon Real
Property and interest in
rights to real property.
Under R.A. 1125, as amended by
RA9282:
Sec. 11 – NO APPEAL shall be taken to
the Court of Tax Appeals (CTA) from the
decision of the Commissioner of Internal
Revenue, on a disputed assessment that
shall suspend payment, levy distraint,
and or sale of any property of the
taxpayer for the satisfaction of his tax
liability, unless the CTA suspends the
collection under certain conditions.
Sec. 13 – Upon issuance of any ruling,
order or decision of the CTA favorable to
the national government, the CTA shall
issue an order authorizing the BIR to
seize and distraint any goods, chattels,
or effects, and other Personal property of
whatever character.
Sec. 218 of the tax code – No court
(except CTA) shall have the authority to
grant an injunction to restrain the
collection of any national internal
revenue tax, fee or charge imposed by
said code.
III. REMEDIES OF THE TAXPAYER (Based on BIR REVENUE REGULATIONS NO. 18-2013)

Pre-Assessment Notice (PAN)

(15 days to file answer)

Final Assessment Notice (FAN)

(30 days)

PROTEST

(30 days)

Appeal to CTA Division

(15 days)

MR to CTA Division

(15 days)

Appeal to CTA En Banc

(15 days)

PETITION FOR REVIEW (SC)

Notice of Informal Conference (OMITTED)
BIR REVENUE REGULATIONS NO. 18-2013
amended Section 3 of RR 12-99 by deleting
Section 3.1.1 thereof which provides for the
preparation of a Notice of Informal Conference.
A. Pre-Assessment Notice (PAN)
If after review and evaluation by the
Commissioner or his duly authorized
representative, as the case may be, it is
determined that there exists sufficient basis to
assess the taxpayer for any deficiency tax or
taxes, the said Office shall issue to the taxpayer
a Preliminary Assessment Notice (PAN) for the
proposed assessment. It shall show in detail the
facts and the law, rules and regulations, or
jurisprudence on which the proposed
assessment is based.
If the taxpayer fails to respond within fifteen (15)
days from date of receipt of the PAN, he shall be
considered in default, in which case, a Formal
Letter of Demand and Final Assessment Notice
(FLD/FAN) shall be issued calling for payment of
the taxpayer's deficiency tax liability, inclusive of
the applicable penalties.
If the taxpayer, within fifteen (15) days from date
of receipt of the PAN, responds that he/it
disagrees with the findings of deficiency tax or
taxes, an FLD/FAN shall be issued within fifteen
(15) days from filing/submission of the
taxpayer’s response, calling for payment of the
taxpayer's deficiency tax liability, inclusive of the
applicable penalties.
NOTE ON PAN:
The failure to strictly comply with the
requirement of sending a PAN before a FAN is
tantamount to DENIAL OF DUE PROCESS.
Conversely, the only instances wherein a PAN
shall NOT be required include the following
cases:
(a) When the finding for any deficiency tax
is the result of mathematical error in the
computation of the tax as appearing on
the face of the return; or
(b) When a discrepancy has been
determined between the tax withheld
and the amount actually remitted by the
withholding agent; or
(c) When a taxpayer who opted to claim a
refund or tax credit of excess creditable
withholding tax for a taxable period was
determined to have carried over and
automatically applied the same amount
claimed against the estimated tax
liabilities for the taxable quarter or
quarters of the succeeding taxable year;
or
(d) When the excise tax due on excisable
articles has not been paid; or
(e) When the article locally purchased or
imported by an exempt person -- such
as, but not limited to, vehicles, capital
equipment, machineries and spare parts
-- has been sold, traded or transferred to
non-exempt persons.
Accordingly, both the sending of the PAN and
the FAN is mandatorily required to inform the
taxpayer of his liability for deficiency taxes. If
only the FAN is issued, the requirements of due
process are deemed unsatisfied, and the
assessment shall be deemed VOID AB INITIO.
B. FINAL ASSESSMENT NOTICE (FAN)
The Formal Letter of Demand and Final
Assessment Notice (FLD/FAN) shall be issued
by the Commissioner or his duly authorized
representative. The FLD/FAN calling for payment
of the taxpayer's deficiency tax or taxes shall
state the facts, the law, rules and regulations, or
jurisprudence on which the assessment is
based; otherwise, the assessment shall be void.
Disputed Assessment. — The taxpayer or its
authorized representative or tax agent may
protest administratively against the aforesaid
FLD/FAN within thirty (30) days from date of
receipt thereof. The taxpayer protesting an
assessment may file a written request for
reconsideration or reinvestigation defined as
follows:
(i) Request for reconsideration —
refers to a plea of re-evaluation of an
assessment on the basis of existing
records without need of additional
evidence. It may involve both a
question of fact or of law or both.
(ii) Request for reinvestigation — refers
to a plea of re-evaluation of an
assessment on the basis of newly
discovered or additional evidence
that a taxpayer intends to present in
the reinvestigation. It may also
involve a question of fact or of law or
both.
If the taxpayer fails to file a valid protest against
the FLD/FAN within thirty (30) days from date of
receipt thereof, the assessment shall become
final, executory and demandable. No request for
reconsideration or reinvestigation shall be
granted on tax assessments that have already
become final, executory and demandable.
 C. PROTEST
The taxpayer shall submit all relevant supporting
documents in support of his protest within sixty
(60) days from date of filing of his letter of
protest, otherwise, the assessment shall become
final.
If the protest or administrative appeal, as the
case may be, is denied, in whole or in part, by
the Commissioner, the taxpayer may appeal to
the CTA within thirty (30) days from date of
receipt of the said decision. Otherwise, the
assessment shall become final, executory and
demandable. A motion for reconsideration of
the Commissioner’s denial of the protest or
administrative appeal, as the case may be,
shall not toll the thirty (30)-day period to
appeal to the CTA.
If the protest or administrative appeal is not
acted upon by the Commissioner within one
hundred eighty (180) days counted from the date
of filing of the protest, the taxpayer may either:
(i) appeal to the CTA within thirty (30) days from
after the expiration of the one hundred eighty
(180)-day period; or (ii) await the final decision of
the Commissioner on the disputed assessment
and appeal such final decision to the CTA within
thirty (30) days after the receipt of a copy of
such decision.
It must be emphasized, however, that in case of
inaction on protested assessment within the
180-day period, the option of the taxpayer to
either: (1) file a petition for review with the CTA
within 30 days after the expiration of the 180-day
period; or (2) await the final decision of the
Commissioner or his duly
D. APPEAL TO THE CTA E. APPEAL TO THE SUPREME COURT
The Court of Tax Appeals was created under RA If the CTA En Banc renders unfavorable decision
1125. It is a special court of limited jurisdiction or denied the appeal to en banc, the taxpayer
particularly in the field of tax collection cases. adversely affected by the decision may file with
RA 9282 expanded the jurisdiction of the CTA, the Supreme Court a petition for certiorari under
elevating it rank to the level of a collegiate court Rule 45.
(CA) with special jurisdiction and likewise
expanding its membership. The Court recognizes that the CTA, which by its
very nature of its function is dedicated
Failure of a taxpayer to appeal from an exclusively to the consideration of tax problems,
assessment on time rendered the assessment has necessarily developed an expertise on the
final, executory and demandable. Consequently, subject, and its conclusion will not be overturned
petitioner is precluded from disputing the unless there has been an abuse or improvident
correctness of the assessment. exercise of authority. Such findings can only be
disturbed on appeal if they are not supported by
In Ker and Company, ltd. V. Court of Tax substantial evidence or there is a showing of
Appeals, the Court held that while the right to gross error or abuse on the part of the tax court.
appeal a decision of the Commissioner to the In the absence of any clear and convincing proof
CTA is merely a statutory remedy, nevertheless to the contrary, the Court must presume that the
the requirements that it must be brought within CTA rendered a decision which is valid in every
30 days is jurisdictional. If a statutory remedy respect. (Barcelon Roxas Sec. v. CIR)
provides a condition precedent that the action to
enforce it must be commenced within a
prescribed time, such a requirement is
jurisdictional and failure to comply therewith
may be raised in a motion to dismiss.
The failure to comply with the 30-day statutory
period would bar the appeal and deprive the
Court of Tax Appeals its jurisdiction to entertain
and determine the correctness of the
assessment.
A party adversely affected by a resolution of a
Division of the CTA on a motion for
reconsideration or new trial, may file a petition
for review with the CTA En Banc.
INCOME TAX REFUND (Sec 229 NIRC) REFUND ON INPUT TAX CREDIT (Sec 219 NIRC)

"In any case, no such suit or

proceeding shall be filed
after the expiration of two
(2) years from the date of
payment of the tax or
penalty regardless of any
supervening cause that may
arise after payment:

Provided, however, That the

Commissioner may, even
without a written claim
therefor, refund or credit any
tax, where on the face of the
return upon which payment
was made, such payment
appears clearly to have been
erroneously paid.

ILLUSTRATION:

ABC Corporation files Income
tax Return on 4/15/2015, the
last day to file Tax Refund
shall be 4/15/2017.
1. If ABC Corp. files a tax refund on 4/10/2016 and an adverse
decision was received on 3/1/2017, he may appeal within 30
days.
2. If ABC Corp. files a tax refund on 4/10/2016 and received an
adverse decision only on 4/10/2017, he has only 5 days to file
appeal with the CTA division as the action will prescribe on
4/15/2017. The filing of refund does not toll the 2-year
prescriptive period for filing tax refund.
3. If ABC Corp. filed a tax refund on 4/10/2016 and the decision
has not been rendered a day or days before 4/15/2017. It may
be considered as implied denial and Appeal may be made on or
before 4/15/2017.
ILLUSTRATION: ABC Corp. VAT-Registered is into export trading, it
purchased goods amounting to 1M plus 12% equivalent to 120,000 on
01/05/2014. It sold the goods on export basis on 5/5/2014.
 The sale was made on 5/5/2014 (Second qtr) and the close of 2 nd Qtr
is 06/30/2014, therefore Refund may be filed up to 06/30/2016.
1. If ABC Corp. filed a written claim for refund on 06/30/2015. He may
file an appeal upon receipt of adverse decision, or if NO ACTION was
made after 120 days, he may file an appeal within 30 days upon the
lapse of 120-day period.
2. If ABC Corp. filed a written claim for refund on 06/01/2016 or a month
before the action prescribes, he still has to wait for 120 days to lapse
before an appeal may be made with 30 days upon the lapse of 120-
day period.
 The taxpayer shall give the government 120 days to resolve the claim
for refund.
 The “120+30-day rule” is mandatory and jurisdictional.
INCOME TAX REFUND (Sec. 229 NIRC)
SECTION 229. Recovery of Tax Erroneously or Illegally Collected. - No suit or proceeding shall be maintained in
any court for the recovery of any national internal revenue tax hereafter alleged to have been erroneously or
illegally assessed or collected, or of any penalty claimed to have been collected without authority, or of any sum
alleged to have been excessively or in any manner wrongfully collected, until a claim for refund or credit has been
duly filed with the Commissioner; but such suit or proceeding may be maintained, whether or not such tax,
penalty, or sum has been paid under protest or duress.

"In any case, no such suit or proceeding shall be filed after the expiration of two (2) years from the date of
payment of the tax or penalty regardless of any supervening cause that may arise after payment: Provided,
however, That the Commissioner may, even without a written claim therefor, refund or credit any tax, where on
the face of the return upon which payment was made, such payment appears clearly to have been erroneously
paid.

National Internal Revenue Code; income tax; creditable withholding tax; refund; requisites. There are three
essential conditions for the grant of a claim for refund of creditable withholding income tax, to wit: (1) the claim is
filed with the Commissioner of Internal Revenue within the two-year period from the date of payment of the tax;
(2) it is shown on the return of the recipient that the income payment received was declared as part of the gross
income; and (3) the fact of withholding is established by a copy of a statement duly issued by the payor to the
payee showing the amount paid and the amount of the tax withheld therefrom. Commissioner of Internal Revenue
v. Team (Philippines) Operations Corporation (formerly Mirant Phils., Operation Corporation), G.R. No. 179260,
April 2, 2014.

National Internal Revenue Code; income tax; tax credit or refund; corporations; irrevocability rule. In case
the corporation is entitled to a tax credit or refund of the excess estimated quarterly income taxes paid, the excess
amount shown on its final adjustment return may be carried over and credited against the estimated quarterly
income tax liabilities for the taxable quarters of the succeeding taxable years. Once the option to carry-over and
apply the excess quarterly income tax against income tax due for the taxable quarters of the succeeding taxable
years has been made, such option shall be considered irrevocable for that taxable period and no application for
cash refund or issuance of a tax credit certificate shall be allowed therefor. Commissioner of Internal Revenue v.
Team (Philippines) Operations Corporation (formerly Mirant Phils., Operation Corporation), G.R. No. 179260,
April 2, 2014.

Court of Tax Appeals; findings and conclusions of the CTA are accorded highest respect. The findings and
conclusions of the Court of Tax Appeals (CTA) are accorded the highest respect and will not be lightly set aside.
The CTA, by the very nature of its functions, is dedicated exclusively to the resolution of tax problems and has
accordingly developed an expertise on the subject unless there has been an abusive or improvident exercise of
authority. Consequently, its conclusions will not be overturned unless there has been an abuse or improvident
exercise of authority. Its findings can only be disturbed on appeal if they are not supported by substantial
evidence or there is a showing of gross error or abuse on the part of the Tax Court. In the absence of any clear
and convincing proof to the contrary, the Court must presume that the CTA rendered a decision which is valid in
every respect. Commissioner of Internal Revenue v. Team (Philippines) Operations Corporation (formerly Mirant
Phils., Operation Corporation), G.R. No. 179260, April 2, 2014.
INPUT TAX REFUND FOR UNUTILIZED INPUT TAX CREDIT ON ZERO-RATED
TRANSACTIONS (Sec 112 of NIRC)

"SECTION 112. Refunds or Tax Credits of Input Tax. -

"(A) Zero-rated or Effectively Zero-rated Sales. - Any VAT-registered person, whose sales are zero-rated or
effectively zero-rated may, within two (2) years after the close of the taxable quarter when the sales were made,
apply for the issuance of a tax credit certificate or refund of creditable input tax due or paid attributable to such
sales.

National Internal Revenue Code; value-added tax; zero-rated or effectively zero-rated sales; unutilized
input value-added tax; claims for tax credit or refund; period to file appeal with the Court of Tax Appeals.
Section 112 (D) of the National Internal Revenue Code provides the Commissioner of Internal Revenue a 120-day
period from submission of complete documents in support of the administrative claim within which to act on claims
for refund/applications for issuance of the tax credit certificate. Upon denial of the claim or application, or upon
expiration of the 120-day period, the taxpayer only has 30 days within which to appeal said adverse decision or
unacted claim before the CTA, otherwise, said judicial claim shall be considered as filed out of
time. Commissioner of Internal Revenue v. Silicon Philippines, Inc. (formerly Intel Philippines Manufacturing,
Inc.), G.R. No. 169778, March 12, 2014.

National Internal Revenue Code; value-added tax; unutilized input VAT; claims for tax credit or refund;
prescriptive periods. (1) An administrative claim must be filed with the Commissioner of Internal Revenue (CIR)
within two years after the close of the taxable quarter when the zero-rated or effectively zero-rated sales were
made. (2) The CIR has 120 days from the date of submission of complete documents in support of the
administrative claim within which to decide whether to grant a refund or issue a tax credit certificate. The 120-day
period may extend beyond the two-year period from the filing of the administrative claim if the claim is filed in the
later part of the two-year period. If the 120-day period expires without any decision from the CIR, then the
administrative claim may be considered to be denied by inaction. (3) A judicial claim must be filed with the Court
of Tax Appeals (CTA) within 30 days from the receipt of the CIR’s decision denying the administrative claim or
from the expiration of the 120-day period without any action from the CIR. (4) All taxpayers can rely on Bureau of
Internal Revenue Ruling No. DA-489-03 from the time of its issuance on December 10, 2003 up to its reversal by
the Court in the Aichi case on October 6, 2010, as an exception to the mandatory and jurisdictional 120+30 day
periods. Commissioner of Internal Revenue v. Silicon Philippines, Inc. (formerly Intel Philippines Manufacturing,
Inc.), G.R. No. 169778, March 12, 2014.
 PROCEDURE IN CUSTOMS PROTEST CASES
COLLECTOR –
Appraisal, Classification, Assessment &
Collection

Payment under protest within 30 days after discharge of

last package
PAY TARIFF AND DUTIES UNDER PROTEST
Filing of Protest with the Collector within 15 days after
payment
FILE PROTEST WITH THE COLLECTOR
Issuance of order of hearing within 15 days
from receipt of protest. When the protest is in
proper form, Collector shall re-examine the
matter presented.
COLLECTOR CONDUCTS HEARING

COLLECTOR DENIES PROTEST – COLLECTOR SUSTAINS PROTEST – If

If the Collector denies the protest the Collector grants the protest
filed by the taxpayer, the taxpayer filed by the taxpayer, the decision
must file a Notice of Appeal to the is adverse to the government, and
Collector within 15 days from hence, there will be an Automatic
notice, copy furnish the Review by the Commissioner.
Commissioner.
The records of the case shall be
The Collector shall transmit all elevated to the Commissioner of
the records of the proceeding to Customs for Automatic Review within
the Commissioner. 5 days from the promulgation.

AUTOMATIC REVIEW BY THE

APPEAL TO THE COMMISSIONER
(The Commissioner shall render
COMMISSIONER a decision within 30 days from
receipt of the records of the
case.
If the Commissioner
If the commissioner AFFIRMS the decision of
renders a decision the Collector granting
ADVERSE to the the protest or NO
government, there will DECISION was rendered
be an automatic Appeal. within 30 days
AUTOMATIC APPEAL AUTOMATIC REVIEW
TO THE SEC. OF TO THE SEC. OF
FINANCE FINANCE

If the decision of the Sec. of Finance is

If the Sec. still adverse to Government or no decision If the Sec. of
of Finance after 30 days, the decision appealed from Finance
renders becomes renders
decision FINAL AND EXECUTORY. decision
adverse to adverse to the
the taxpayer, taxpayer, he
he may still may still file
file an an appeal with
appeal with the CTA.
APPEAL TO THE CTA
the CTA. If the Commissioner
If the commissioner REVERSED the decision
renders a decision of the Collector, the
adverse to the Taxpayer may appeal to
TAXPAYER, He may the CTA within 30
appeal to the CTA days.
within 30 days

APPEAL TO
SC