COURT OF TAX APPEALS Mandated Function

The Court shall exercise the following mandated functions: A. . Exclusive appellate jurisdiction to review by appeal, as herein provided: Decisions of the Commissioner of Internal Revenue in cases involving! (APFRO) " disputed assessments, #" penalties in relation thereto, $" fees or other charges, %" refunds of internal revenue taxes, or &" other matters arising under the 'ational (nternal )evenue Code or other laws administered by the *ureau of (nternal )evenue! #. Inaction by t e Co!!i""ioner of Interna# Re$enue in cases involving disputed assessments, refunds of internal revenue taxes, fees or other charges, penalties in relation thereto, or other matters arising under the 'ational (nternal )evenue Code or other laws administered by the *ureau of (nternal )evenue, where the 'ational (nternal )evenue Code provides a specific period for action, in which case the inaction shall be deemed a denial! %eci"ion"& order" or re"o#ution" of t e Re'iona# Tria# Court" in local taxes originally decided or resolved by them in the exercise of their original or appeallate jurisdiction! %eci"ion" of t e Co!!i""ioner of Cu"to!" in cases involving liability for customs duties, fees or other charges, sei+ure, detention or release of property affected, fines, forfeitures or other penalties in relation thereto, or other matters arising under the Customs ,aw or other laws administered by the *ureau of Customs! %eci"ion" of t e Centra# (oard of A""e""!ent Appea#" in t e e)erci"e of it" appea##ate *uri"diction over cases involving the assessment and taxation of real property originally decided by the provincial or city board of assessment appeals! %eci"ion" of t e Secretary of Finance on cu"to!" ca"e" e#e$ated to i! auto!atica##y for re$ie+ fro! deci"ion" of t e Co!!i""ioner of Cu"to!" which are adverse to the .overnment under /ection #$ & of the Tariff and Customs Code!

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%eci"ion" of t e Secretary of Trade and Indu"try , in the case of nonagricultural product, commodity or article, and the Secretary of A'ricu#ture in the case of agricultural product, commodity or article, involving dumping and countervailing duties under /ection $1 and $1#, respectively, of the Tariff and Customs, and safeguard measures under )epublic Act 'o. 2211, where either party may appeal the decision to impose or not to impose said duties. 3urisdiction over cases involving criminal offenses as herein provided: E)c#u"i$e ori'ina# *uri"diction o$er a## cri!ina# offen"e" ari"in' fro! $io#ation" of t e ,ationa# Interna# Re$enue Code or Tariff and Cu"to!" Code and other laws administered by the *ureau of (nternal )evenue or the *ureau of Customs. E)c#u"i$e appe##ate *uri"diction in cri!ina# offen"e" : 4ver appeals from the *ud'!ent"& re"o#ution" or order" of t e Re'iona# Tria# Court" in ta) ca"e" ori'ina##y decided by t e! , in their respective territorial jurisdiction. 4ver petition" for re$ie+ for t e *ud'!ent"& re"o#ution" or order" of t e Re'iona# Tria# Court" in t e e)erci"e of t eir appe##ate *uri"diction o$er ta) ca"e" ori'ina##y decided by t e Metropo#itan Tria# Court", 5unicipal Trial Courts and 5unicipal Circuit Trial Courts in their respective jurisdiction. 3urisdiction over ta) co##ection ca"e" as herein provided: Exclusive original jurisdiction in ta) co##ection ca"e" in$o#$in' fina# and e)ecutory a""e""!ent" for ta)e"& fee"& c ar'e"& and pena#tie" : 6rovided, however, that collection cases where the principal amount of taxes and fees, exclusive of charges and penalties, claimed is less than 4ne million pesos 7 ,111,111.11" the same shall be tried by the proper 5unicipal Trial Court, 5etropolitan Trial Court and )egional Trial Court. Exclusive appe##ate *uri"diction in ta) co##ection cases: 4ver appeals from the *ud'!ent"& re"o#ution" or order" of t e Re'iona# Tria# Court" in ta) co##ection ca"e" ori'ina##y decided by t e!, in their respective territorial jurisdiction. 4ver petition" for re$ie+ of t e *ud'!ent"& re"o#ution" or order" of t e Re'iona# Trai# Court" in t e e)erci"e of t eir appea##ate *uri"diction over tax collection cases originally decided by the 5etropolitan Trial Courts, 5unicipal Trial Courts and 5unicipal Circuit Trial Courts, in their respective jurisdiction.

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3udgments or final orders of the above Courts are appe##ab#e to t e di$i"ion of t e Court of Ta) Appea#" +it in fifteen (-.) day" fro! notice of the judgment or final order or resolution or from the denial of the motion for new trial or reconsideration.

The deci"ion of t e di$i"ion i" in turn appea##ab#e +it in fifteen (-.) day" to t e CTA en banc. The deci"ion of t e CTA en banc i" direct#y appea##ab#e to t e Supre!e Court on /ue"tion of #a+ on certiorari. 7under )ule %$"