The following are the grounds in the nullity of an assessment:

1. If the assessment notice does not contain a demand to pay.

2. If the assessment notice does not indicate a definite amount of tax liability.
3. If the assessment notice does not have a due date.
4. If the assessment notice was not preceded by a Letter of Authority or LOA.
5. If the assessment notice was not preceded by a Notice of Informal
Conference (NIC).
6. If the assessment does not provide for the facts and the law upon which the
assessment was based.
7. If the assessment was not issued within the prescriptive period.
8. If the assessment was not sent and received by the taxpayer.
9. If the assessment was not addressed to the taxpayer.
10.If there was no Preliminary Assessment Notice (PAN), except on the
following instances:
a. Mathematical Error on the computation of tax liability.
b. Taxpayer applied for excess payment and the same has been carried
over by the taxpayer on the next taxable years.
c. Discrepancy between the amount of tax withheld and the tax remitted
d. Excise Tax on the excisable articles has not been paid.
e. When goods exempt from taxes has been transferred or sold by an
exempt entity to a non-exempt entity.