Here is the translation:
1. Subject of Dispute: Challenging a tax notification-decision on imposing penalties for late registration of tax invoices.
2. Key Arguments of the Court:
– The court analyzed a complex legal situation regarding the application of moratoriums on penalties during quarantine and martial law
– It was established that provisions of the “COVID” moratorium ceased to be effective from May 27, 2022
– Procedural issues regarding the legal capacity of the plaintiff – Representation of a foreign company – were identified
3. Court Decision: To cancel previous court decisions and refer the case for a new hearing to clarify procedural issues and ultimately resolve the dispute on its merits.
Note: The court essentially deviated from previous practice regarding the interpretation of moratoriums on penalties.
