LandmarkTaxation Law

Quartz Business Products v. CIR

No confirmed citationMay 1, 2025

Study material, not legal advice. Written and checked by the PhilippineLaws team to the best of our knowledge; not reviewed by a lawyer. A digest is a summary — the full decision is the authority, so read it before you cite it.

Don't cite this from here. The docket on file (G.R. No. 2025-CTA-QUARTZ) could not be matched to any decision in the library, so it is not shown as a citation above. The case may well be real — find the reported citation before you use it.

Cited for

Actual Receipt Rule

Why it matters

Income tax can only be imposed when there is actual or constructive receipt of income representing a realized gain. Mere computerized data matching by the BIR — without proof of actual receipt — is insufficient basis for a deficiency income tax assessment.

Digest

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