The Court of Tax Appeals (CTA) has nullified the more than P2.2 billion income tax liabilities slapped by the Bureau of Internal Revenue (BIR) against boxing great and former Senator Manny Pacquiao for violating his right to due process.

The court's Special Third Division stated that the BIR did not notify Pacquiao and his wife, Jinkee, who was included in the case, when it issued the preliminary and final assessment notices to settle the back accounts.

It cited Section 228 of the Tax Code which says "taxpayers shall be informed in writing of the law and facts on which the assessment is made, otherwise the assessment shall be void."

The resolution also noted the assessment "lacks sufficient basis," as it was sourced mainly from newspaper and magazine clippings that reported Pacquiao's multi-million-dollar income for successfully defending his various international boxing titles in the United States in 2008 and 2009.

"In sum, the court finds that the assessment for deficiency income tax is void for violation of the petitioners' right to due process and for lack of factual basis," said Associate Justice Erlinda P. Uy who wrote the 49-page verdict.

The assessment against the boxing legend also included his share from pay per view and closed circuit television sale.

The deficiency tax covered purely income tax as the former solon readily settled the more than P31 million deficiency value-added tax assessment due from his earnings in promoting wide range of local products.

Pacquiao was the top individual taxpayers of the BIR in 2008, but rank number 113th the following year.