Who determines what documents are relevant and sufficient for a reinvestigation?

• A. The BIR
• B. The CTA
• C. The Court
• D. The taxpayer

Answer: (D)

In reinvestigation, the line of evidentiary control rests with the party seeking to justify their position. The taxpayer, who has firsthand knowledge of their facts and access to the supporting records, decides which documents are most relevant and sufficient to substantiate their claim. The tax authority will then review and evaluate those documents to determine their relevance and adequacy, and may request additional information if needed. The Court and the appellate bodies do not determine the initial set of documents during the reinvestigation; they assess the evidence after it has been submitted and during subsequent proceedings.