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Question

The Bill of Rights: Due Process Clause, Procedural and Substantive Requirements

Anne, a taxpayer, received a notice of assessment from the Bureau of Internal Revenue (BIR) stating that she has a deficiency tax liability amounting to Php 1,000,000. She believes that the assessment is unjust and without legal basis. Anne decides to contest the assessment and files a protest with the BIR. However, the BIR denies her protest and issues a final decision upholding the deficiency tax assessment.

Feeling aggrieved, Anne decides to seek redress before the appropriate judicial body to challenge the assessment. Applies the provisions of the 1987 Constitution, specifically the Due Process Clause on procedural and substantive requirements (Art. III, Sec. 1).

1. What are the procedural requirements that Anne needs to adhere to when challenging the assessment before the judicial body?
2. What are the substantive requirements that Anne must prove to show that the assessment is unjust and without legal basis?

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Answer