g. Preliminary Assessment Notice

Validity of Tax Assessments and Administrative Due Process

In tax assessment proceedings, administrative due process is satisfied when the taxpayer is granted the opportunity to be heard and submit evidence, and the Commissioner of Internal Revenue duly considers such evidence in the proceedings, such as in the Final Decision on Disputed Assessment (Level Up, Inc. v. CIR, G.R. No. 272354, 29 September 2025¹).

A tax assessment is considered prima facie valid and lawful unless shown to be arbitrary or capricious (Level Up, Inc. v. CIR¹). Consequently, the affected taxpayer bears the burden of proving that the questioned assessment is erroneous or invalid (Level Up, Inc. v. CIR¹). Where the assessment involves the disallowance of creditable input taxes, such input taxes are creditable against output taxes only if supported by VAT invoices or official receipts compliant with statutory invoicing requirements under Section 110(A)(1) of the National Internal Revenue Code; mere summary lists of purchases do not suffice (Level Up, Inc. v. CIR¹).