Here is the translation:
1. Subject of Dispute: Challenging tax notifications-decisions regarding the imposition of penalties for late payment of rent for subsoil use.
2. Key Arguments of the Court:
– The controlling authority credited the paid funds towards repayment of the existing tax debt, which automatically led to the accrual of penalty sanctions
– The court noted that previous courts did not establish key circumstances – whether advance payments were agreed upon at all
– Legislation clearly regulates the procedure for crediting taxpayer funds regardless of their will
3. Court Decision: To cancel previous court decisions and refer the case for a new review to establish all factual circumstances.
