In cases where taxpayers do not agree with the estimates of tax assessment officer, it has the right to appeal against the assessment to the Commission of Appeals according to section 30 of the Revenue Code. The appeals Considering section 31 paragraph 2 provide that in case where the decision of Commission of Appeals orders to pay more tax, the appellant shall pay within the time limit but actually present in the Supreme Court has decision that the Commission of Appeals does not have the power to orders to pay more tax or repeal the assessment.