Likewise, in Solid-One Mills Phils. Inc. vs CIR (CTA Case 8507, May 29, 2014), the CTA held that the BIR had five years to collect the tax assessed even when the assessment was made within the three-year regular period (thus, no fraud was involved). ... Contrary to the Sunnyphil and Solid-One Mills cases, however, the recent Supreme …
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