Supreme Court dismisses extraordinary review due to lack of gross legal violation despite unconstitutional tax penalty application.

The Supreme Court dismissed the extraordinary review filed by the President of the Administrative Court against a tax authority decision. Although the lower court incorrectly applied a Constitutional Court ruling regarding the unconstitutionality of a specific tax penalty provision, the Supreme Court found the substantive application of that penalty to the taxpayer lacked legal basis. Consequently, the court held that the procedural defects in the lower court's reasoning did not constitute a gross violation of law sufficient to overturn the decision.