06-02-2019, 02:47 PM
General Rule
The Government is not bound by the errors committed by its agents. In the performance of its government functions, the State cannot be estopped by the neglect of its agents and officers (CIR vs. CTA, GR No. 106611, July 21, 1994).
Reason
Upon taxation depends the Government's ability to serve people for whose benefit taxes are collected. to safeguard such interest, neglect or omission of government officials entrusted with the collection of taxes should not be allowed to bring harm or detriment to the people
Exception
The CIR is precluded from adopting a position inconsistent with the one previously taken where injustice would result therefrom or where there has been a misrepresentation to the taxpayer (Balmaceda vs. Corominas, GR No. L-21971, Sept. 5, 1975).
The Government is not bound by the errors committed by its agents. In the performance of its government functions, the State cannot be estopped by the neglect of its agents and officers (CIR vs. CTA, GR No. 106611, July 21, 1994).
Reason
Upon taxation depends the Government's ability to serve people for whose benefit taxes are collected. to safeguard such interest, neglect or omission of government officials entrusted with the collection of taxes should not be allowed to bring harm or detriment to the people
Exception
The CIR is precluded from adopting a position inconsistent with the one previously taken where injustice would result therefrom or where there has been a misrepresentation to the taxpayer (Balmaceda vs. Corominas, GR No. L-21971, Sept. 5, 1975).