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of <h1>Amendment to Circular No. 3 (2018) mandates contesting tax cases with constitutional issues or undisclosed foreign assets.</h1> The amendment to paragraph 10 of Circular No. 3 of 2018 revises the guidelines for contesting adverse judgments in tax-related cases. Regardless of the monetary limits specified, cases should be contested if they involve constitutional challenges, illegal or ultra vires Board orders, accepted Revenue Audit objections, undisclosed foreign income or assets, information from law enforcement agencies, or pending prosecutions. This modification is effective immediately and should be communicated to all relevant officers. The amendment has been approved by the Finance Minister and aims to ensure critical issues are addressed on their merits.
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