CTA voids P51.6-M BIR withholding tax assessment vs JTKC Land

The Court of Tax Appeals (CTA) voided a P51.59 million deficiency withholding tax assessment issued by the Bureau of Internal Revenue (BIR) against property developer JTKC Land, Inc., ruling that the assessments lacked legal basis and were partly issued without valid audit authority. BusinessWorld reported that the decision was promulgated on June 30.

In a 30-page decision, the CTA Special First Division found that the BIR failed to establish the factual and legal basis for the assessment. The court noted that the revenue officer who conducted the audit lacked the required Letter of Authority, invalidating the entire process.

The ruling is a significant win for JTKC Land, which had challenged the assessment before the CTA. The BIR's claim for deficiency withholding taxes was set aside, reinforcing the principle that tax assessments must strictly comply with statutory requirements.