EconomyEditor's PickTax court affirms Robinsons Land’s canceled tax worth P3.76M

January 24, 2023

THE Court of Tax Appeals (CTA) has affirmed its ruling that set aside Robinsons Land Corp.’s (RLC) tax liabilities worth P3.76 million including penalties and interests for the fiscal year 2009.

In a 38-page decision on Jan. 17 and made public on Jan. 20, the CTA full court denied the commissioner of internal revenue’s (CIR) appeal to overturn the ruling since it was filed late.

The country’s revenue code mandates that a motion for reconsideration must be filed within 15 days to dispute a court ruling.

“All told, the decision dated July 9, 2020 of the court’s first division had already attained finality because of the petitioner’s (CIR) belated filing of his motion for reconsideration,” according to the ruling penned by Associate Justice Lanee S. Cui-David.

“Under the doctrine of immutability of judgment, the said decision may no longer be modified even if it is meant to correct an erroneous conclusion of law and facts of the court in division,” the magistrate added.

Under the tax court’s rules, litigants must prove their compliance with the 15-day period mandated under the tax code before the tribunal can hear the appeal.

The CTA First Division had voided the CIR’s final letter of demand and final assessment notice because they did not show definite due dates for payment, which violated RLC’s right to due process.

Citing a Supreme Court ruling, it said that tax demand letters that fail to provide a specific due date of payment must be nullified.

The tribunal said the CIR did not comply with the tax code’s due process requirement when the official did not explain why RLC’s arguments to dispute the assessment were rejected.

Tax assessments that fail to afford a taxpayer due process must be voided, according to the country’s tax code.

“The right to be heard, which includes the right to present evidence, is meaningless if the Commissioner can simply ignore the evidence without reason,” it said.

“A party’s fundamental right to due process includes the right to be informed of the various issues involved in a proceeding and the reasons for the decision rendered by the quasi-judicial agency.” — John Victor D. Ordoñez

Leave a Reply

Your email address will not be published. Required fields are marked *

Disclaimer:, its managers, its employees, and assigns (collectively “The Company”) do not make any guarantee or warranty about what is advertised above. Information provided by this website is for research purposes only and should not be considered as personalized financial advice. The Company is not affiliated with, nor does it receive compensation from, any specific security. The Company is not registered or licensed by any governing body in any jurisdiction to give investing advice or provide investment recommendation. Any investments recommended here should be taken into consideration only after consulting with your investment advisor and after reviewing the prospectus or financial statements of the company.

Copyright © 2023 SmartPeopleMail. All Rights Reserved.

Subscribe for FREE today and get your daily shot of smart news about the Economy and Investing.
We are dedicated to keeping any data we collect from you — safe and secure. Here you can read our privacy policy.