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ATC vs. CIR

ASIAN TRANSMISSION CORPORATION, PETITIONER, V. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

G.R. No. 230861 | 2018-09-19

D E C I S I O N
 
BERSAMIN, J.:
 
We reiterate through this decision that the taxpayer has the primary responsibility for the proper preparation of the waiver of the prescriptive period for assessing deficiency taxes. Hence, the Commissioner of Internal Revenue (CIR) may not be blamed for any defects in the execution of the waiver.
 
The Case
 
This appeal seeks the review and reversal of the decision promulgated on August 9, 2016,[1] whereby the Court of Tax Appeals En Banc (CTA En Banc) reversed and set aside the decision rendered by its Second Division (CTA in Division) holding that the waivers executed...