Subject of Dispute: Challenging the Legitimacy of Penalty Sanctions for Late Registration of Tax Invoices during Martial Law.
Main Arguments of the Court:
1. The court established that the plaintiff violated the deadline for registering tax invoices during the period from February 2022 to May 2023 but did not apply to the controlling authority with a statement about the impossibility of fulfilling tax obligations.
2. The Supreme Court clearly defined that after May 27, 2022, the “COVID” moratorium was terminated, and taxpayers could no longer rely on automatic exemption from penalty sanctions.
3. The court emphasized that the regulations on tax invoice registration during martial law have a clear temporal structure with different rules for different periods.
Court Decision: To leave the cassation complaint unsatisfied, confirming the legitimacy of penalty sanctions imposed by the controlling authority.
