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Case No. 520/7034/19 dated 19/03/2025

Here is the translation:

Subject of Dispute: Challenging tax notifications-decisions by which the Main Directorate of the State Tax Service increased the monetary obligations of LLC “RAT” for income tax and VAT.

Main Arguments of the Court:
1. The plaintiff’s business transactions with counterparties are real and confirmed by primary documents.
2. The court deviated from previous judicial practice, which considered that transactions of fictitious enterprises cannot be legalized.
3. The controlling authority did not prove that the company acted in bad faith or without due diligence in conducting business transactions.

Court Decision: To leave unchanged the decisions of previous instances and to deny the Main Directorate of the State Tax Service satisfaction of the cassation complaint, that is, to cancel the tax notifications-decisions.

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