How does a review applicant put rebuttal evidence before the tax authorities, and who then carries it to the offices that hold the file?
General information · Not legal advice
Material to check
In a practice file we read the opinion the applicant was sent under the preceding provision, so that the evidence can be seen as answering it; the Commissioner's request stating the period for submission, and the receipt or dispatch record showing what was handed over, when, and to which office.
These are types of material to look for, not evidence already verified by PRO SE.
Where readings differ
One reading follows the chain the provision sets out: the applicant for a request for review may submit evidence documents or objects to the Commissioner of the National Tax Service to rebut the opinion received, and where the Commissioner requires submission by setting a period, the applicant must submit within that period.
Another reading notes that the copy duty rests on the Commissioner alone: once evidence documents are submitted, the Commissioner must send a copy without delay to the head of the relevant tax office and the director of the regional tax office, so the applicant's papers need only reach the Commissioner, and the provision leaves open what the deadline period must be or what follows if it is missed.
Your judgment
If the set period has passed and only the tax office has the applicant's papers, how could the file show whether the evidence ever reached the Commissioner in time?
PRO SE does not make this decision or keep a case record on this public site.When to reconsider
We revisit this card if the provision is amended to set a consequence for missing the period or to name the office that decides rebuttal evidence, or if a ruling clarifies whether a submission lodged with the tax office director counts as made to the Commissioner.