b. Submission of Supporting Documents by Taxpayer

Submission of Relevant Supporting Documents

Only applies to requests for reinvestigation, i.e., the 60-day period for submission of all relevant supporting documents shall not apply to requests for reconsideration (R.R. No. 18-2013)¹

Relevant Supporting Documents

The taxpayer shall submit all relevant supporting documents in support of his request for reinvestigation within 60 days from date of filing of such written request. Otherwise, the FAN shall become final. (NIRC, Sec. 228², R.R. No. 18-2013³)

“Relevant supporting documents” refers to those documents necessary to support the legal and factual bases in disputing a tax assessment as determined by the taxpayer. (R.R. No. 18-2013)

The relevant supporting documents mentioned in the law refer to such documents which the taxpayer feels would be necessary to support his protest and not what the CIR feels should be submitted. Otherwise, the taxpayer would always be at the mercy of the CIR which may require production of such documents which taxpayer could not produce. (Standard Chartered Bank v. CTA, CTA Case No. 5696⁴)

The BIR cannot demand what type of supporting documents should be submitted (CIR v. First Express Pawnshop Company, G.R. No. 172046⁵). For a request for reinvestigation, however, the taxpayer must submit supporting documents within 60 days from filing the protest; otherwise, the assessment becomes final.

Effect of Non-Submission of Relevant Supporting Documents

For a request for reinvestigation, failure to submit relevant supporting documents within 60 days from filing the protest renders the assessment final (R.R. No. 12-99, as amended by R.R. No. 18-2013⁶). The 60-day supporting-document requirement does not apply to a request for reconsideration (NIRC, Sec. 228).