Here is the translation:
1. Subject of Dispute: Challenging tax notifications-decisions of LLC “AMBRA IMPEKS” regarding additional tax liabilities and penalty sanctions.
2. Main Arguments of the Court:
– The plaintiff’s business transactions with counterparties are of a real nature
– Primary documents comply with legislative requirements
– Lack of fixed assets by counterparties is not grounds for recognizing transactions as unreal
– The tax authority did not prove the artificial nature of business transactions
3. Court Decision: The case has been referred for a new review to conduct a detailed analysis of each episode of additional tax liability assessment.
Key feature of the decision is a critical approach to the formal interpretation of business transactions by tax authorities.
