Supreme Court dismissed extraordinary review, ruling export tax exemption requires actual physical export of goods.

The Supreme Court dismissed the extraordinary review against the tax office's decision to deny an export tax exemption. The taxpayer argued that a verbal contract and customs stamps proved export, but authorities found a seal was forged and the goods never crossed the border. The court held that the statutory requirement for physical export existed prior to the new regulation, making the lack of actual movement fatal to the exemption claim.