G.R. No. 239221 - Seacrest Maritime Management, Inc., Nordis Tankers Marine A/S, and Redentor Anaya vs. Samuel B. Bernarte

South Entertainment Gallery, Inc. (SEGI) is a domestic corporation operating bingo and games of chance in SM City Pampanga.
On June 8, 2009, SEGI was assessed for deficiency income tax (P7,653,329.00) and VAT (P26,126,960.17) for taxable year 2007 via Notice of Informal Conference and subsequent Preliminary Assessment Notice (PAN).
SEGI invoked its tax-exempt status under PAGCOR grants; BIR replied that R.A. No. 9337 repealed the exemption.
On December 9, 2009, BIR issued a Formal Letter of Demand with Details of Discrepancies and Assessment Notice (FLD-DDAN), allegedly received January 13, 2010; on May 28, 2010, Final Notice Before Seizure (FNBS) was issued (received June 16, 2010); on September 1, 2010, a Warrant of Distraint and/or Levy (WDL) was issued.
SEGI requested cancellation of the WDL on September 24, 2010; BIR reiterated deficiency assessments via letter dated March 28, 2011 (received April 13, 2011).

CTA Third Division (April 15, 2014) partly granted SEGI’s petition: cancelled notices relating to VAT but upheld deficiency income tax.
On SEGI’s motion, CTA Division (July 7, 2014) reversed its April 2014 decision and cancelled all notices for lack of proof of valid service.
CTA En Banc (October 28, 2015) affirmed the Division’s amended decision and denied BIR’s motion for reconsideration; BIR’s motion denied March 22, 2016.
Commissioner of Internal Revenue (CIR) filed a petition for review on certiorari under Rule 45 to the Supreme Court.

Whether the CTA had jurisdiction to entertain SEGI’s petition for review (timeliness).
Whether the FLD-DDAN was validly served on SEGI under the applicable rules.
Whether the deficiency assessments and attendant collection notices are valid, and whether SEGI retains any tax-exempt status.