Constitutional complaint regarding validity of tax assessment

The Constitutional Court upheld the challenged provision, effectively rejecting the constitutional complaint and allowing the administrative decision to stand. The dispute concerned a tax assessment, specifically challenging the lawfulness of a levy or penalty imposed by the tax authorities on the complainant. The decisive legal basis involved the interpretation of the relevant provisions of the General Tax Code (Abgabenordnung) and the Constitution, with the Court determining that the legislative enactment did not violate the principle of legal certainty or the right to property, thereby affirming the constitutionality of the norms applied by the lower administrative bodies.