Subject of Dispute: Challenging a Tax Notification-Decision on Applying Penalties for Late Registration of Tax Invoices during Martial Law.
Main Arguments of the Court:
1. Despite martial law, the taxpayer is obligated to register tax invoices within the timeframes established by law.
2. The taxpayer must prove the impossibility of fulfilling the tax obligation by submitting a corresponding application to the controlling authority, rather than simply referring to martial law.
3. Systematic violation of invoice registration deadlines indicates the ability to fulfill the tax obligation, rather than objective impossibility.
Court Decision: Partially satisfy the claim by canceling penalties amounting to 3,396.12 UAH for improperly charged fines.
