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CIR vs. AVON

COMMISSIONER OF INTERNAL REVENUE, PETITIONER, V. AVON PRODUCTS MANUFACTURING, INC., RESPONDENT. [G.R. Nos. 201418-19, October 3, 2018] AVON PRODUCTS MANUFACTURING, INC., PETITIONER, V. THE COMMISSIONER OF THE INTERNAL REVENUE, RESPONDENT.

G.R. Nos. 201398-99 | 2018-10-03

D E C I S I O N
 
LEONEN, J.:
 
Tax assessments issued in violation of the due process rights of a taxpayer are null and void. While the government has an interest in the swift collection of taxes, the Bureau of Internal Revenue and its officers and agents cannot be overreaching in their efforts, but must perform their duties in accordance with law, with their own rules of procedure, and always with regard to the basic tenets of due process.
 
The 1997 National Internal Revenue Code, also known as the Tax Code, and revenue regulations allow a taxpayer to file a reply or otherwise to submit comments or arguments with supporting...