Why is it important to uphold the statute of limitations in tax assessment and collection, as explained in CIR v. Philippine Global Communications, Inc.?

• A. It protects the Government only.
• B. It provides certainty only for taxpayers.
• C. It promotes fairness, stability, and orderly tax administration only.
• D. It protects both Government and taxpayer, providing certainty and promoting fairness, etc.

Answer: (D)

Upholding the statute of limitations gives finality and predictability in tax matters. It prevents endless or open-ended claims, which helps the government plan and administer revenue collection, while also shielding taxpayers from indefinite uncertainty about their liabilities. In CIR v. Philippine Global Communications, Inc., the court highlights that the time limits on assessment and collection protect both sides: they safeguard government revenue by ensuring claims are pursued promptly, and they protect taxpayers by providing certainty and stability for financial planning. This combination promotes fairness, stability, and orderly tax administration. Other options focus on only one side or a single aspect, but the decision recognizes that the limit serves a dual protection, delivering certainty and fairness to both government and taxpayer.