Supreme Court quiesced a tax ruling due to a contradiction between its decision and reasoning under administrative procedure law.

The Supreme Court quiesced a lower administrative court's tax ruling because the decision's operative part contradicted its reasoning regarding VAT deduction rights. The taxpayer argued that the court failed to properly address why specific invoices could not be used for offsetting tax, while the court claimed the invoices were invalid due to lack of supporting copies and unverified construction work. The court held that while the reasoning contained errors, the specific contradiction between the decision and reasoning violated procedural requirements, necessitating the case's remittal for reconsideration.