Subject of Dispute: Challenging a Tax Notification-Decision of the Large Taxpayers Office of the State Tax Service regarding violation of tax invoice registration deadlines.
Main Arguments of the Court: The court established that during the inspection, the controlling authority improperly documented the circumstances of untimely registration of several tax invoices, as they fell outside the inspection period. At the same time, the courts of previous instances did not provide a legal assessment of the timeliness of registration of two tax invoices that were within the inspection period, which constitutes a significant procedural violation.
Court Decision: To cancel the decisions of the courts of previous instances and refer the case for a new review to the court of first instance for a complete and comprehensive investigation of the case circumstances.
