

Issue:
► Are the deficiency
income tax and VAT assessments valid?
Ruling:
► No. The PAN and Formal Letter of Demand are
void because they do
not state the law and the facts on which the assessments were based in
violation of Section 228 of the Tax Code.
CTA Case No. 8128 dated November 22, 2011
Legal and Factual bases required in PAN
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