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CIR vs. South Entertainment Gallery, Inc.

COMMISSIONER OF INTERNAL REVENUE, PETITIONER, VS. SOUTH ENTERTAINMENT GALLERY, INC., RESPONDENT.

G.R. No. 223767* | 2023-04-24

D E C I S I O N
 
GESMUNDO, C.J.:
 
Taxing authorities may serve the required notices upon the taxpayer personally or through substituted service. They are not excused from complying with the requirements of a valid substituted service even if the taxpayer's registered or known address is located inside an establishment with a central receiving station. It is incumbent upon them to prove the fact of such service through the attestation of at least two revenue officers other than the revenue officer serving the notice. Strict compliance with the requirements of substituted service is essential in ensuring the right of the taxpayer...