Here is the translation:
1. Subject of Dispute: Challenging the order of the Main Tax Service Directorate regarding conducting an actual inspection and actions related to drawing up an act on the impossibility of conducting an inspection.
2. Main Arguments of the Court:
– The court first formulated a clear legal position regarding the content of the inspection order
– The order did not contain specific information about the grounds for conducting the inspection
– Reference only to subsection 80.2.5 of the Tax Code of Ukraine is insufficient
– The inspection report does not create legal consequences for the enterprise
3. Court Decision: Declare the order for conducting an actual inspection unlawful and cancel it, deny other claims.
Key novelty – detailed explanation of requirements for drafting inspection orders by controlling authorities.
