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    Case No. 560/2984/24 dated 20/03/2025

    Subject of Dispute: Challenging a Tax Notification-Decision on Imposing Penalties for Violation of the Procedure for Conducting Settlement Transactions and Issuing Settlement Documents.

    Main Arguments of the Court:

    1. The court changed its previous position regarding the assessment of grounds for conducting an actual inspection, noting that reference to subsection 80.2.5 of the Tax Code is a sufficient basis for inspection.

    2. The absence of a digital value of the excise tax stamp barcode in the fiscal receipt deprives such a document of the status of a settlement document, which is a violation of the legislation.

    3. Information from the System of Accounting of Cash Register Operation Data (SOD RRO) can be used by the controlling body as an independent source of information during the inspection.

    Court Decision: To cancel the decisions of previous instances and refer the case for a new review for comprehensive investigation of circumstances.

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