The Court of Tax Appeals (CTA) has erased the P179.9 million tax liabilities of a businessman from Isabela for the failure of the Bureau of Internal Revenue (BIR to give him a chance to answer the tax assessments.
The court's First Division said the assessments issued to Joselito B. Yap, owner of JAPI Enterprises of Cauayan City, were void "for improper services of letters of authority to investigate and assessment notices" as required under Revenue Regulations 12-99.
Associate Justice Marian Ivy F. Reyes-Fajardo, who wrote the decision, said the the tax documents were received by non-employee of the trucking service company and not by it's authorized representative.
She added that the same papers were not sent to the registered address of the taxpayer, but to one of its branch offices as confirmed by the BIR's witness during the trial.
As a result, the 33-page resolution stated "there was failure to inform the taxpayer of the legal and factual bases of the assessments."
The assessments covered three-year period starting in 2021 and included deficiency income and value-added taxes.