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A domestic corporation, ApexNova Manufacturing, Inc., received a Notice of Assessment from the BIR for deficiency corporate income tax and civil penalties arising from underreporting gross receipts in the prior year. The Notice shows a base tax deficiency of PHP 3,200,000 and civil penalties totaling PHP 640,000. The BIR Commissioner approves a compromise: pay PHP 2,150,000 in full within 21 days, and all civil penalties are waived; the case is closed. A year later, it is discovered that the underreporting stemmed from a clerical error in the accounting records rather than willful evasion. The BIR now questions the validity of the compromise and whether criminal liability could still be pursued. (a) Identify the controlling doctrine on compromise penalties under the NIRC and related BIR rules. (b) Distinguish compromise of civil penalties from other remedies and state the limits of the government’s authority to grant or deny such compromises. (c) Apply to the facts: Is the compromise valid and binding? Could the government still pursue criminal liability or other remedies? Explain.