CIR vs.PHILIPPINE-ALUMINUM WHEELS, INC. G.R. No. 216161

Facts:
Respondent is a corporation organized and existing under Philippine laws which engages in the manufacture, production, sale, and distribution of automotive parts and accessories. BIR issued a Final Assessment Notice (FAN) against respondent in the amount of ₱32,100,613.42 Respondent requested for reconsideration of the FAN issued by the BIR.  BIR issued a Final Decision on Disputed Assessment (FDDA) and demanded full payment of the deficiency tax assessment from respondent. Respondent filed with the BIR an application for the abatement of its tax liabilities. BIR denied respondent’s application for tax abatement on the ground that the FDDA was already issued by the BIR and that the FDDA had become final and executory due to the failure of the respondent to appeal the FDDA with the CTA.

Issue:
Whether respondent is entitled to the benefits of the Tax Amnesty Program under RA 9480.

Held:
The Acceptance of Payment Form, the Notice of Availment, the SALN, and the Tax Amnesty Return shall be submitted to the RDO, which shall be received only after complete payment. The completion of these requirements shall be deemed full compliance with the provisions of RA 9480. Respondent’s completion of the requirements of the Tax Amnesty Program under RA 9480 is sufficient to extinguish its tax liability under the FDDA of the BIR. The FDDA issued by the BIR is not a tax, case “subject to a final and executory judgment by the courts” as contemplated by Section 8(f) of RA 9480. The determination of the tax liability of respondent has not reached finality and is still not subject to an executory judgment by the courts as it is the issue pending before this Court.

credit to: Fritz de Castro