PRIME STEEL MILL, INCORPORATED, PETITIONER, VS. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
- G.R. Number: G.R. No. 249153
- Promulgated: 2022-09-12
- Ponente: DIMAAMPAO, J.
Keywords
Section 203 National Internal Revenue Code, Section 228 Tax Code, Revenue Regulations No. 12-99, Section 15 Rule 44 Rules of Court, Section 1 Rule 14 A.M. No. 05-11-07-CTA, Section 3 Rule 1 A.M. No. 05-11-07-CTA, Due Process in Tax Assessment, Strict Compliance with Tax Assessment Procedures, Presumption of Correctness of Tax Assessments, Change of Theory on Appeal (Exceptional Circumstances), Tax Assessment, Deficiency Income Tax, Tax Due Process, Tax Collection, Petition for Review on Certiorari, Preliminary Assessment Notice (PAN), Final Assessment Notice (FAN), Formal Letter of Demand (FLD), Final Decision on Disputed Assessment (FDDA), Prescription