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Case No. 580/3134/22 dated 31/03/2025

Here is the translation:

1. Subject of Dispute: Challenging tax notifications-decisions issued by the controlling authority during the moratorium on conducting inspections during the quarantine period.

2. Main Arguments of the Court:
– Paragraph 52-2 of Subsection 10 of Section XX of the Tax Code of Ukraine established a moratorium on conducting inspections during quarantine.
– Resolution of the Cabinet of Ministers of Ukraine No. 89 on reducing the moratorium period cannot modify the norms of the Tax Code.
– The court clearly indicated that an inspection conducted during the moratorium does not create legal consequences and is illegal.

3. Court Decision: The cassation appeal of the Main Directorate of the State Tax Service in Cherkasy Oblast was left without satisfaction, and the appellate court’s resolution on cancellation of tax notifications-decisions was left unchanged.

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