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Question
DeltaLine Industries, a corporation subject to corporate income tax, receives an NIRC assessment dated December 10, 2024, for deficiency in corporate income tax for the year 2023 in the amount of PHP 18,000,000, with payment due January 12, 2025. It does not pay by the due date. On January 25, 2025, the BIR issues a separate delinquency notice for failure to pay on time for the period January 1–January 31, 2025. On February 28, 2025, DeltaLine pays PHP 7,000,000. On April 15, 2025, DeltaLine pays the remaining PHP 11,000,000 plus applicable interest and surcharges. (a) Distinguish whether the PHP 18,000,000 is tax deficiency or tax delinquency, and explain why. (b) Did delinquency attach in DeltaLine’s case, and does the payment on February 28 cure the delinquency or merely extinguish the deficiency? (c) What remedies or recourses does DeltaLine have to challenge the deficiency or the delinquency and to protect its interests going forward?