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Basic Components of Tax Accounting

0 Views· 11/26/23
Aryel Narvasa
Aryel Narvasa
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stamped as received, of the Acceptance Payment Form, and the Tax Amnesty on Delinquencies Return shall be deemed as sufficient proof of availment: Provided, furthermore, That the Tax Amnesty on Delinquencies Return and the Acceptance Payment Form shall be submitted to the Revenue District Office after complete payment. The completion of these requirements shall be deemed full compliance with the provisions of this Act. Upon full compliance with all the conditions set forth in this Title and payment of the corresponding tax on delinquency, the tax amnesty granted under this Title shall become final and irrevocable.
The ATCA or NIATCA is so important to me because it will be one of my relevant proof that my existing and pending civil, criminal and administrative cases are already closed and terminated. For this purpose, the governing law is shown in the next page.
Section 20, RA 11213. The tax delinquency of those who avail of the Tax Amnesty on Delinquencies and have fully complied with all the conditions set forth in this Act and upon payment of the amnesty tax shall be considered settled and the criminal case under Section 18(c) and its corresponding civil or administrative case, if applicable, be terminated, and the taxpayer shall be immune from all suits or actions, including the payment of said delinquency or assessment, as well as additions thereto, and from all appurtenant civil, criminal, and administrative cases, and penalties under the National Internal Revenue Code of 1997, as amended, as such relate to the taxpayer’s assets, liabilities, networth, and internal revenue taxes that are subject of the tax amnesty, and from such other investigations or suits insofar as they relate to the assets, liabilities, networth and internal revenue taxes that are subject of the tax amnesty
Furthermore, the following jurisprudence must be taken importance to come up with a relevant decision.
“It is an elementary rule of construction that when the language of the law is clear and unequivocal, the law must be taken to mean exactly what it says (Banawa vs. Miranon, 97 SCRA 533). Its literal meaning should be followed (Tan Lin vs. Republic, 2 SCRA 386); to depart from the meaning expressed by the words is to alter the statute (Commissioner of Internal Revenue vs. Central Luzon Drug Corporation, 492 SCRA 581). Equally settled is the rule that the law cannot be amended by a mere regulation. An administrative agency may not enlarge, alter or restrict the provisions of the statute being administered (Pilipinas Kao, Inc. vs. Court ofAppeals, 372 SCRA 573). It may not engraft additional non-contradictory requirements on the statute which were not contemplated by the legislature. In fact, a regulation that 'operates to create a rule out of harmony with the statute is a mere nullity' (Commissioner of Internal Revenue vs. Central Luzon Drug Corporation, supra. 582). Considering that RA 9480 specifically enumerated the persons and cases that are not covered by the Tax Amnesty Law, those enumerated therein cannot be enlarged or restricted by a mere Revenue Memorandum Circular. Otherwise, the Revenue Memorandum Circular will alter the statute it seeks to implement. Second, under Section 2(a) of Revenue Regulations 17-86, a "delinquent account" is defined as the amount of tax due on or before December 31, 1985 from a taxpayer who failed to pay the same, within the time prescribed for its payment arising from (1) a self assessed tax, whether or not a tax return was filed, or·(2) a deficiency assessment issued by the BIR which has become final and executory. CTA No. 7779”
SUPREME COURT.
Also by tradition and in our system of judicial administration, the Supreme Court has the last word on what the law is; it is the final arbiter of any justiciable controversy. There is only one Supreme Court from whose decisions all other courts should take their bearings. (G.R. No. 150947, July 15, 2003) I encourage this Honourable Office and its key officials to pray with me and ask the Almighty God that (a) this shall be accepted and acknowledged upon presentment; (b) all the available and legal reliefs and remedies that favour me shall be dispensed without mental reservation and purpose of evasion; and (c) all the correct, admissible and important actions to be accomplished in reply to the legal issues and simple requests herein presented should consciously be made in writing and delivered to me, within three (3) working days from receipt hereof.
All criminal complaints filed with the DOJ and courts for the taxable years 2017 and prior years shall be DISMISSED, CLOSED AND TERMINATED immediately due to the fact that my Application for Tax Amnesty’s immunities and privileges had become final and irrevocable.

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