Once an evaluation is made or issued, the taxpayer can't choose to pay the assessment and thereafter seek a refund at any time within the full period of two (2) years from the date of cost as Section 196 of LGC of 1991, as amended, might counsel. The Court ruled that Section 195 of the LGC of 1991, as amended, requiring the filing of a protest would still apply even if the taxpayer opts to pay the amount assessed within the same interval of 60 days and online Slots subsequently claims for refund under Section 196 of the identical legislation.
Here, since the Billing Assessment Forms had been issued to the taxpayer and so they qualify because the notices of evaluation contemplated by law, it could not observe Section 196 of the LGC of 1991, free online slots as amended, without complying with the requirement of filing a protest beneath Section 195 of the same regulation. On the contrary, Casino slots Section 196 of the LGC of 1991, Casino slots as amended, would apply, Free slots without requiring prior slots game compliance with Section 195, if no notice of evaluation was issued to the taxpayer.
In ruling in opposition to the CIR, the Court held that the time period "relevant supporting documents" for purposes of the above-quoted Section 228 of the 1997 NIRC, as amended, refers to the documents essential to assist the legal basis in disputing a tax assessment, as decided by the concerned taxpayer and not by the BIR. The latter can solely inform the former to submit extra documents, but the BIR cannot demand what type of supporting documents must be submitted.
To rule otherwise would, in effect, free online slots place the taxpayer at the mercy of the BIR, which may require the manufacturing of paperwork which mentioned taxpayer may not be capable to submit. In the same vein, it isn't correct for the taxpayer to acknowledge mentioned erroneously handed-on VAT as input taxes. Consequently, this failure on the part of the taxpayer ought to result in the denial of its declare for input VAT refund.
The Commission cannot tolerate and ignore any act or omission on the a part of those concerned in the capital market which would violate the norm set by the securities legislation particularly on the transactions and duties of Broker Dealers and Casino slots that would diminish or even simply are inclined to diminish the faith of the buyers on the integrity of the capital market.