Supreme Court dismissed extraordinary review, ruling tax losses during exemption periods cannot offset future taxable income.

The Supreme Court dismissed the extraordinary review against a tax authority decision regarding a company's 1994 tax liability. The tax office denied deductions for losses incurred in 1991, a period covered by a tax exemption, arguing that such losses are economic risks rather than taxable deductions. The court upheld this stance, reasoning that the purpose of tax exemption is not to assume the taxpayer's business risk, thereby preventing the offset of losses generated during the non-taxable period.