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Lumina Manufacturing Corp., a Philippine corporation engaged in electronics assembly, is controlled by President Adrian Chen and CFO Mia Torres. They implement a scheme to evade taxes by contracting a shell service provider, Stratus Consulting Ltd., registered in a non-resident jurisdiction, which issues invoices for management services that are never rendered. The company records these invoices as deductible expenses in both the general ledger and the corporate income tax return, while no actual services were provided and no legitimate business purpose exists for the payments. The BIR audit uncovers the fraudulent entries and assesses deficiency taxes and penalties. Is Lumina Manufacturing Corp. liable for tax evasion under the NIRC?