G.R. No. 143530 - Altizo vs. BRYC-V Development Corp.

Pursuant to Letter of Authority No. 00042459, the BIR conducted a tax audit of Mannasoft Technology Corporation for CY 2008, issuing a Notice of Informal Conference (NIC) and Preliminary Assessment Notice (PAN) purportedly served on “Ms. Gladys Badocdoc, Client Service Assistant.”
On November 16, 2011, the BIR issued a Formal Assessment Notice (FAN) finding deficiencies of:

The FAN was stipulated to have been served on “Angelo Pineda,” a reliever security guard.

Mannasoft protested the FAN on December 22, 2011, submitted supporting documents on February 20, 2012; the BIR allegedly did not evaluate these and, on October 23, 2012, issued a Warrant of Distraint and/or Levy (WDL). Mannasoft protested the WDL as premature and requested reinvestigation on November 13, 2012.
The BIR denied reinvestigation in a letter received November 25, 2013, stating it was its “final decision.” Mannasoft filed a petition for review with the CTA on December 10, 2013.
The CTA Third Division (Jan. 13, 2017) canceled the assessments and WDL for due process violations in service. The CTA En Banc (June 19, 2018) reversed, holding the WDL final and dismissing for lack of timely appeal. Reconsideration was denied (Jan. 18, 2019). Mannasoft elevated to the Supreme Court.

Did the CTA En Banc err in interpreting its “other matters” jurisdiction under Section 7(a)(1) of RA 1125 (as amended) to hinge solely on receipt of the WDL?
Was the petition for review before the CTA timely filed—i.e., should the 30-day period run from receipt of the WDL or from receipt of the BIR’s final denial of reinvestigation?

Should the CTA En Banc have considered the assessments void for lack of due process in service of the NIC, PAN, and FAN?
Does an invalid assessment render the subsequent WDL void?