TIMED TASK

University of Saint Bangtan ("USB") is a stock, proprietary educational institution with registered business address in Sangandaan, Caloocan City. For the taxable year ending 2021, USB generated revenues from tuition fees amounting to P10,000,000, revenues from its leasing activities amounting to P6,000,000, and revenues from selling books and school supplies amounting to P3,000,000. The Bureau of Internal Revenue ("BIR) assessed USB of deficiency income taxes, contending that all amounts are subject to tax. USB filed its protest, contending that in accordance with the Constitution, it is exempt from all taxes and duties. The BIR, without refuting, proceeded to summarily seize USB's assets and ordered the closure of USB. What constitutional limitation did the BIR violate? Fiscal adequacy Non-taxability of educational institutions Equal protection clause Procedural due process