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CIR V Liquigaz Case Digest
CIR V Liquigaz Case Digest
It also received a copy of the PAN on May 20, 2008 and was assessed
23,931,708.72 PHP as deficiency tax.
It received the copy of FDDA on July 1, 2010 and still liable for
22,380,025.19 PHP
However, a void FDDA does not ipso facto render the assessment void. A
decision differs from an assessment. An assessment becomes a disputed
assessment after a taxpayer has filed its protest to the assessment. The
CIR either issues a decision on the disputed assessment or fails to act on it
and is considered denied. The taxpayer may then appeal the decision on
the disputed assessment or the inaction of the CIR. As such, the FDDA is
not the only means that the final tax liability of a taxpayer is fixed, which
may then be appealed by the taxpayer.
REMANDED TO CTA