1. The subject of the dispute is the lawfulness of the appellate court’s decision to leave an agricultural firm’s lawsuit seeking the cancellation of a tax authority’s decision to refuse registration of a tax invoice without consideration, due to the expiration of the statute of limitations for filing the lawsuit.
2. In this case, the Supreme Court upheld the legal position of the Grand Chamber of the Supreme Court dated July 16, 2025 (case No. 500/2276/24), which clearly distinguishes between appeal periods depending on whether the taxpayer utilized the pre-trial appeal procedure and whether the dispute concerns the accrual of monetary liabilities. The Court emphasized that the issue of the validity of reasons for missing a deadline is a matter of assessment and requires the court to conduct a detailed analysis of all circumstances presented by the plaintiff, rather than merely formally stating the fact that the deadline was missed. The appellate court erred by focusing solely on the fact of the plaintiff’s previous application to the court, while ignoring other arguments regarding objective obstacles (shelling, lack of communication, illness of the director, etc.). The Supreme Court stressed that the strict application of procedural deadlines during martial law without considering real circumstances may constitute a form of excessive formalism that limits the right of access to justice. Therefore, the court is obligated to provide a proper legal assessment of each of the plaintiff’s arguments regarding the validity of the reasons for missing the deadline before leaving the lawsuit without consideration.
3. The Supreme Court overturned the appellate court’s ruling and remanded the case to the appellate court for further proceedings.
