MANILA — The Court of Tax Appeals (CTA) has denied an appeal filed by a local car dealer challenging additional tax assessments imposed by the Bureau of Customs (BOC) in 2021.

In a 15-page ruling dated May 18, the CTA en banc rejected the petition for review filed by Rising Cars Corp., an importer of car parts, and affirmed an earlier decision of its division.

“(T)he Court finds no reversible error in the assailed resolutions of the Court in division,” the ruling, written by Associate Justice Lance S. Cui-David, stated.

The case stemmed from a September 2021 demand by the Deputy District Collector of the Port of Batangas requiring the payment of additional taxes based on valuation by the BOC Imports and Assessments Service.

Rising Cars Corp. disputed the valuation and paid ₱3.05 million but later pursued legal action after receiving a subsequent resolution from a district collector.

The CTA division dismissed the petition in April 2024, finding procedural lapses in the company’s appeal.

The court ruled that appeals should have first been elevated to the BOC Commissioner rather than directly challenged, and noted that the filing of the petition in November 2023 was beyond the allowable period.

“The filing of the petition for review only in November 2023, more than two years thereafter, was clearly out of time,” the CTA said.

With the ruling, the tax court effectively upheld the BOC’s assessment and rejected the company’s challenge for lack of merit.