Payments made during tax assessments cannot be refunded
IN Commissioner of Internal Revenue v Toledo Power Corp. (GR 259309, Feb. 13, 2023) (the Toledo Case), the Supreme Court overturned the findings of the Court of Tax Appeals (CTA) both in division and en banc, and held that payments voluntarily made by a taxpayer in the course of a tax assessment cannot later be refunded in favor of the taxpayer.
Supreme Court Bureau Of Internal Revenue Revenuev Toledo Power Corp Internal Revenue Toledo Power Toledo Case
Source: manilatimes.net