Subject of Dispute: Challenging Tax Notifications-Decisions on Land Tax Accrual for 2021 and 2022.
Main Arguments of the Court: The Supreme Court drew attention that the term for filing a lawsuit to cancel a tax notification-decision is six months and is calculated from the day when a person learned or should have learned about the violation of their rights. The court emphasized that the appellate instance did not clarify the circumstances regarding the date of receipt of tax notifications by the plaintiff, which is a significant shortcoming in the case review.
Court Decision: The cassation complaint was partially satisfied, the appellate court’s ruling was canceled, and the case was referred for a new review to the appellate instance to clarify all circumstances of the case.
