pilipinas shell vs cir

PILIPINAS SHELL vs. CIRFacts:FIRST ASSESSMENTPetitioner Pilipinas Shell, a Philippine subsidiary of the international petroleum iant Shell, and is enaed in the importation, refininand sale of petroleum products in the country! It "as ranted Ta# $redit $ertificates %T$$& by the 'ept! of Finance by the 'uty'ra"bac( $enter %$enter in bre)ity&! Pilipinas Shell used the T$$s in payment of some of its e#cise ta# liabilities!*n April ++, ,--., the /IR sent a collection letter012to Pilipinas Shell for alleed deficiency e#cise ta# liabilities of PhP,,345,4+.,44.!46 for the ta#able years ,--+ and ,--1 to ,--3, inclusi)e of delin7uency surchares and interest! As basis for thecollection letter, the /IR alleed that Pilipinas Shell is not a 7ualified transferee of the T$$s it ac7uired from other /*I8reisteredcompanies!Pilipinas Shell protested the collection letter, but the protest "as denied by the /IR! Pilipinas Shell filed its motion for reconsideration!9o"e)er, due to respondent:s inaction on the motion, Pilipinas Shell filed a petition for re)ie" before the $TA!$TA ruled that the use by Pilipinas Shell of the T$$s "as leal and )alid, and that respondent:s attempt to collect alleed delin7uentta#es and penalties from Pilipinas Shell "ithout an assessment constitutes denial of due process! Respondent ele)ated the case tothe $A ; still pendin to date!SE$*N' ASSESSMENT: T9IS IS 4 days from receipt of the disputed assessment letter!9E@':