Commercial and Taxation Laws › Taxation Law › Tax Remedies › Taxpayer Remedies › Decision of CIR on Protest

iii. Effect of Failure to Appeal

The decision becomes final, executory and demandable

If a final decision on a disputed assessment is received and no appeal is filed within the applicable 30-day period, the decision becomes final, executory and demandable.1

Inaction alone does not make the assessment final

Inaction after 180 days does not by itself make the assessment final if the taxpayer chooses to await the final decision. Lascona Land Co., Inc. v. CIR, G.R. No. 171251, 5 March 2012.

Effect of Failure to Appeal

Effect of Failure to Appeal to CTA: The decision shall be final, executory and demandable

Authorities

  • Lascona Land Co., Inc. v. CIR, G.R. No. 171251, 5 March 2012
  • NIRC Sec. 228