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Question
Axion Tech, Inc., a VAT-registered taxpayer, receives an NIRC assessment dated April 18, 2026, for deficiency in output VAT for March 2026 in the amount of PHP 8,400,000, with payment due May 12, 2026. It does not pay by the due date. On May 28, 2026, the BIR issues a separate delinquency notice for failure to pay on time for the period March 1–March 31. On June 22, 2026, Axion pays PHP 2,000,000. On July 30, 2026, Axion pays the remaining PHP 6,400,000 plus applicable interest and surcharges. (a) Distinguish whether the PHP 8,400,000 is tax deficiency or tax delinquency, and explain why. (b) Did delinquency attach in Axion’s case, and does the payment on June 22 cure the delinquency or merely extinguish the deficiency? (c) What remedies or recourses does Axion have to challenge the deficiency or the delinquency and to protect its interests going forward?