CTA Case
No. 7967 dated January 5, 2012 Necessity of PAN in BIR assessment

Preliminary Assessment Notice (PAN) as prescribed under Revenue
Regulations (RR) No. 12-99. On the other hand, the CIR asserted that the
absence of a PAN did not invalidate the assessment since Mr. Luang was
able to file his protest to the FAN within the period provided by law and
regulations.
Issue:
► Did the absence of a PAN invalidate the
assessment?
Ruling:
*■ Yes. The receipt by the
taxpayer of a PAN is part of the due process
requirement
in the issuance of a deficiency tax assessment, the absence of which nullifies
any assessment made by tax authorities.
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