The Court of Tax Appeals (CTA) has upheld the P508-million deficiency tax assessment imposed by the Bureau of Internal Revenue (BIR) against a four-star hotel on Roxas Boulevard in Pasay City due to its failure to file its protest on time.
The court’s Second Division in a 25-page resolution stated that it lost jurisdiction to decide over the tax liabilities of Palace Hotel Corporation, owner of Heritage Hotel, because the assessment has become mandatory and executory.
Revenue Regulations No. 12-19 which implemented Section 228 of the Tax Code requires a taxpayer to answer the final assessment notice within 30 days upon receipt and 60 days to submit the supporting documents.
Records showed that the hotel received the BIR’s final demand letter on Sep. 19, 2013, but filed its petition for review on Feb. 20, 2015 or 489 days after the lapse of the 30-day period.
The tax debts covered income, value-added and withholding taxes for the year 2008. (Jun Ramirez)