Cassation court dismisses tax agency appeal, ruling retroactive application of procedural term extensions is barred by substantive nature of tax evasion presumptions.

The Court of Cassation rejected the tax agency's appeal against a regional tax commission decision regarding late tax assessment notifications. The agency argued that the 2009 law extending procedural deadlines should apply retroactively to 2008 tax years, while the taxpayer contended the law lacked retroactive effect. The court held that the specific presumptions of tax evasion regarding offshore accounts are substantive rules, meaning the extended procedural deadlines cannot apply to past years.