Coverage.
Section 2
SEC.2. Coverage. – The provisions of this Decree shall apply to income tax liabilities covering the period 1974 to 1979, inclusive, except the following: Criminal cases already filed in Court or with the Fiscal’s Office on or before the effective date of this Decree; Income tax cases involving civil liability which are the subject of a pending criminal action in the Fiscal’s Office or the Court prior to the effectivity of this Decree; Withholding tax at source liabilities provided for in Section 53, 54 and Chapter XI of Title II of the National Internal Revenue Code; and Deficiency income taxes assessed on or before the effectivity of this Decree.