Supreme Court held that administrative debt collection does not render tax waiver proceedings without subject matter.

The Supreme Court quashed the Supreme Administrative Court's decision dismissing a tax waiver request after the tax debt was collected via administrative enforcement. The taxpayer argued that the tax obligation had expired due to the collection, making the waiver proceeding pointless, while the tax authority contended the debt's existence invalidated the waiver request. The court ruled that the mere collection of the debt does not automatically deprive the waiver proceeding of its subject matter, thereby upholding the taxpayer's right to seek a waiver.