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In NovaTech Manufacturing, a private corporation that owns a parcel of land used for its factory receives a Notice of Local Property Tax Assessment for the current year, showing a substantial increase in the assessed value due to a reclassification from 'industrial facility' to 'commercial use' and a higher overall value. The corporation files a written protest with the Municipal Treasurer within 25 days from receipt, alleging overvaluation and misclassification. After a hearing, the Treasurer denies the protest in writing. The corporation then files a petition for relief with the Sanggunian within 25 days from receipt of the denial. (a) Identify the controlling doctrine under Protest - Sec. 195 and the remedy available to the taxpayer. (b) Distinguish protest from other remedies and whether filing a protest suspends tax collection. (c) Apply to the facts and determine whether the protest is timely, and what is the proper next step for the taxpayer.

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Clara

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