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PAN issued by Assessment Division shows the facts and

The person who authorized the LOA is the Commissioner or the
Director General, this letter will serve as the official document to
examine taxpayer's book of accounts without this tax
assessment because it will violate the right of taxpayer.
Revenue Officer is allowed in 120 days to conduct the audit
and submit a report of investigation, if the RO unable to submit
a report within 120 days they must surrender the LOA for
revalidation.
The RO who audit the taxpayer records shall state in his report
if the taxpayer is liable for tax if not the taxpayer will be
informed in writing the informal conference to have an
opportunity to present his side of the case.
If the taxpayer fails to respond in 15 days from the date of
receipt of NIC, he shall consider as default.
the law, rules and regulations, or jurisprudence on which
the proposed assessment is based.
If the taxpayer fails to respond within 15 days from the date
of receipt of PAN he shall considered as default which a
formal letter of demand and assessment notice shall be
issued by the Office calling for payment of the taxpayer’s
deficiency tax liability.
Assessment
Dismissed
The formal letter of demand and assessment notice is issued
by the Commissioner this letter is a demand calling for
payment of the taxpayer’s deficiency tax.

The RDO shall endorse the case with least possible delay to
the Assessment Division or to the Commissioner for review
and issuance of deficiency tax assessment, if warranted.

After review or revaluation by the Assessment Division or the

Commissioner if the case is determined that there exists sufficient
basis to assess the taxpayer for any deficiency tax the Office shall
issue to the taxpayer a Preliminary Assessment Notice for the
proposed assessment.
The protest on FLD/FAN shall be addressed to the assistant
commissioner or regional director and filed with the office of the
concerned revenue official to record and evaluate the protest.

Failure to file a valid protest against the FLD/FAN within 30-days period
shall render the deficiency tax assessment final, executory and
Case Dismissed demandable, with no recourse for request for reconsideration or re-
investigation.

When a taxpayer disagrees with a tax assessment, there is a right to register
a protest and provide supporting documentation within the time frame
specified. If a taxpayer files a protest and presents supporting papers within
the appropriate time frame, the Commissioner must consider the protest and
accompanying documentation and render a decision within 180 days. This is
done to guarantee that the taxpayer's case is processed promptly and that
they obtain a decision on their protest within a reasonable length of time. If
the Commissioner does not make a judgment within 180 days, the taxpayer
may have certain rights and remedies.
When the Commissioner rules in favor of the taxpayer, it
signifies that the taxpayer's protest and submission of
supporting papers were effective in convincing the
Commissioner to decrease or remove the tax assessment at
issue. In this instance, the person would usually get a refund or
credit for any overpaid taxes, or their tax burden would be
decreased.
The Commissioner's judgment is in the
taxpayer's favor, the case will be dismissed if
the taxpayer agrees with the decision and has
no plans to take the matter onward.
The Commissioner does not rule on a taxpayer's protest within 180 days,
the taxpayer may file an appeal with the CTA within 30 days of the 180-
day deadline, or they may wait for the Commissioner's final decision
before filing an appeal with the CTA under the Lascuna Doctrine. This
alternative is accessible to the taxpayer, but it may result in further delay
and uncertainty about the result of the litigation.
The taxpayer disagrees with any part of the judgment, they may have
the right to submit an appeal with the Court of Tax Appeals (CTA)
within 30 days of receiving the decision, or they may file a Motion for
Reconsideration (MR) within 30 days of receiving the decision. If the
taxpayer files an MR, the thirty-day grace period for filing an appeal
with the CTA is delayed or suspended until the motion for
reconsideration is decided. The taxpayer will have 30 days from the
day the MR is refused to submit an appeal with the CTA.
If a taxpayer's appeal to the Court of Tax Appeals (CTA) or Motion
for Reconsideration (MR) is allowed, it signifies that the CTA or the
Commissioner, depending on the situation, has ruled in the
taxpayer's favor. A new decision will be issued if the decision is
reversed, amended, or put aside.
 If a taxpayer's appeal or Motion for Reconsideration (MR) to the Court
of Tax Appeals (CTA) is granted, the taxpayer may still appeal the
judgment to the CTA within the 30-day term. If the taxpayer is
dissatisfied with the judgment that was issued, or the taxpayer desires
to seek more relief or clarity on specific topics that were not addressed
in the ruling, he or she may choose this option.
A taxpayer files an appeal with the Court of Tax Appeals (CTA) within the
30-day deadline, the CTA will have authority to hear and consider the matter
at hand. The taxpayer will be allowed to offer evidence and arguments in
support of his or her standpoint, and the CTA will make an assessment
based on the facts and the laws in effect.
If the CTA concludes in the taxpayer's favor, the decision
will be amended, and the taxpayer will no longer be
obligated to pay the taxes or penalties levied by the the
Bureau of Internal Revenue.
And if the CTA's judgment is favorable to the taxpayer, the
next step is to file an MR with the CTA Division within 15
days after receiving the decision. The MR is a procedural
remedy that asks the CTA to rethink its judgment on
specific reasons, and it is usually accompanied by a
written brief or memorandum.
If a Motion for Reconsideration (MR) submitted
within 15 days of the initial decision is approved,
the CTA will issue a new decision that alters or
reverses its earlier judgment. The revised
decision may be more advantageous to the
taxpayer, since it may lower or eliminate the tax
liability or penalties that the Bureau of Internal
Revenue (BIR) initially imposed. If the CTA allows
the MR, the taxpayer may not need to file an
appeal with the Supreme Court since the CTA's
judgment is final and executory. If the CTA rejects
the MR, the taxpayer may still be able to pursue
an appeal with the Supreme Court.
A Motion for Reconsideration (MR) submitted within
15 days with the Court of Tax Appeals (CTA) Division is
granted and the taxpayer is still dissatisfied with the
judgment, the next option is to file an appeal with the
CTA en banc. An appeal to the CTA, which is
comprised up of all of its members and serves as a
body to hear and consider cases of important legal or
constitutional significance. An appeal to the CTA en
banc is a remedy that tries to have the full court
review and evaluate the CTA Division's ruling, which
details the taxpayer's legal and factual grounds.
When the CTA authorizes the appeal en banc, the judgment becomes
final and executory, which means it can no longer be questioned. The
BIR is obligated to carry out the assessment and, if applicable, award a
tax credit or refund to the taxpayer. The CTA en banc is a taxpayer's
final administrative options for settling tax issues. If the taxpayer is still
dissatisfied with the CTA's en banc ruling, he or she may seek an
appeal with the Supreme Court.

If the taxpayer is still unhappy with the CTA's en banc ruling, the next step is
to file an appeal with the Supreme Court. The taxpayer's last legal option for
settling tax problems is to file an appeal with the Supreme Court. The
Supreme Court will solely consider legal issues made in the case and
may amend the CTA's en banc judgment based on its appraisal of the legal
problems raised.

In the end, the outcome of a tax dispute will be determined by the taxpayer's
legal remedies, as well as the judgments of the administrative bodies and
courts engaged in the case. If a taxpayer successfully appeals a Bureau of
Internal Revenue (BIR) decision to the Court of Tax Appeals (CTA) and then to
the Supreme Court, and the final decision is in the taxpayer's favor, the BIR
must comply with the decision and may be required to refund any excess tax
payments made by the taxpayer.

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