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Ardent Manufacturing Co., a VAT-registered taxpayer, receives an NIRC assessment dated May 15, 2025, stating a deficiency in output VAT for April 2025 in the amount of PHP 5,000,000, with payment due June 15, 2025. It does not pay by the due date. On July 3, 2025, the BIR issues a delinquency notice for failure to pay on time for the period April 1–April 30. On July 20, 2025, Ardent pays PHP 2,000,000. On August 25, 2025, Ardent pays the remaining PHP 3,000,000 plus applicable interest and surcharges. (a) Distinguish whether the PHP 5,000,000 is tax deficiency or tax delinquency, and explain why. (b) Did delinquency attach in Ardent’s case, and does the payment on July 20 cure the delinquency or merely extinguish the deficiency? (c) What remedies or recourses does Ardent have to challenge the deficiency or the delinquency and to protect its interests going forward?