In cases of inaction of the CIR on the protested assessment, can these remedies be availed simultaneously?

• A. Yes, both may be pursued concurrently.
• B. No, these options are mutually exclusive.
• C. Only administrative protest is allowed.
• D. Only judicial protest is allowed.

Answer: (B)

The key idea is that challenging a protested assessment offers two alternative routes, and you must choose one of them rather than pursuing both at the same time. You can appeal through an administrative protest with the CIR, asking the agency to review and amend the assessment, or you can go to the Court of Tax Appeals for a judicial resolution of the dispute. These are treated as election of remedies—taking one path precludes simultaneously pursuing the other for the same issue. When the CIR is inaction on the protest, it creates a doorway to the judicial route, but it does not permit concurrent proceedings in both forums. This design avoids duplicative relief and ensures a single, clear process for resolution.