Supreme Court dismissed extraordinary review, ruling tax delay penalties are discretionary but not automatically waived by administrative delays.

The Supreme Court dismissed the extraordinary review filed by the Ombudsman against the Supreme Administrative Court's decision to deny the waiver of tax delay penalties. The Ombudsman argued that the tax authority's significant delays in issuing the assessment decision and initiating proceedings should have triggered a mandatory waiver under the Tax Obligations Act. The court held that while the statute grants discretion to waive penalties for economic or social reasons, the mere passage of time or administrative slowness does not automatically justify such a waiver, as the tax liability and subsequent penalty obligations arose independently of the authority's conduct.