Here is the translation:
1. Subject of Dispute: Challenging tax notifications-decisions regarding additional accrual of income tax and VAT for transactions with counterparties.
2. Key Arguments of the Court:
– Economic transactions must be real, confirmed by primary documents, and cause changes in the taxpayer’s property status
– Insignificant document deficiencies are not grounds for non-recognition of transactions
– The court deviated from its previous position regarding “fictitious enterprises”, noting that the status of an enterprise cannot be a basis for canceling transactions
– The taxpayer is not responsible for possible violations by counterparties if they acted in good faith
3. Court Decision: Uphold previous court decisions and reject the tax authority’s request to cancel tax notifications-decisions.
