Is a VAT assessment void if the taxpayer files a late reply to the PAN? | G.R. No. 272354
In this case, a company challenged a deficiency VAT assessment, arguing that the BIR failed to consider its explanations and supporting documents, allegedly violating Section 228 of the NIRC and due process standards under jurisprudence. The Supreme Court examined whether missing the 15-day reglementary period to reply to the PAN invalidates the assessment and whether due process was still observed during the administrative and judicial stages.
