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Question
An overpayment arises in City of Isla Verde due to the erroneous application of the tax rate for a combined line of business activities. Sunshine Group of Companies, a taxpayer in Isla Verde, paid Local Business Tax (LBT) of PHP 4,600,000 for 2024 after receiving a notice of assessment. A post-audit reveals that the classification of certain activities was misapplied, resulting in an overpayment of PHP 340,000. The City Treasurer denies a cash refund, citing Sec. 196 of the Local Government Code (RA 7160) and states that any overpayment may be credited against future local taxes. Sunshine contends that it is entitled to a cash refund and seeks a cash refund rather than a credit. (a)Identify the controlling doctrine under Sec. 196 regarding refunds or credits of local tax overpayments. (b)Distinguish between a cash refund and a credit, and explain who bears the burden of proof to establish an overpayment and the proper remedy. (c)Apply the doctrine to the facts and determine whether Sunshine Group should be entitled to a cash refund, a credit, or neither, and outline the procedural steps that should follow.