Supreme Court dismissed cassation, ruling tax court reviews decision deadlines, not statute of limitations.

The Supreme Court dismissed the cassation appeal regarding a tax authority's decision on social security contributions. The appellant argued the decision was time-barred, but the court clarified that the court's review focuses on whether the authority met the statutory deadline for issuing the decision under Article 118 of the Tax Procedure Act. The court held that the statute of limitations for the underlying debt is a separate issue from the procedural deadline for the administrative act itself.