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Question XIII

2013 Bar · Taxation · 4 sub-questions

MSI Corp. imports orange and lemon concentrates as raw materials for the fruit drinks it sells locally. The Bureau of Customs (BOC) imposed a 1% duty rate on the concentrates. Subsequently, the BOC changed its position and held that the concentrates should be taxed at 7% duty rate. MSI disagreed with the ruling and questioned it in the CTA which upheld MSI's position. The Commissioner of Customs appealed to the CTA en bane without filing a motion for reconsideration. Resolve the appeal. (1%)
(a)(A) The appeal should be dismissed because a motion for reconsideration is mandatory.
(b)(B) The appeal should be dismissed for having been filed out of time.
(c)(C) The appeal should be given due course since a motion for reconsideration is a useless exercise.
(d)(D) The appeal should be upheld to be fair to the government which needs taxes.

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