Php 2.7 billion tax assessment canceled; Chief of large taxpayer audit division cannot validly sign a memorandum of assignment; PAGCOR’s licensees and contractees are exempt from income tax on gaming revenues
The CTA En Banc affirmed the decision of the CTA Division declaring the assessment void, cancelled and withdrawn. Under the rules, a Memorandum of Assignment (MOA) may be construed as equivalent to new letter of authority where the authority of a newly designated revenue officer emanates from, provided that it contains