Supreme Court dismissed extraordinary review for failing to prove gross violation of objective truth principle regarding tax decision delivery date.
Legislator summary
AI generatedThe Supreme Court dismissed the extraordinary review against a tax authority's decision to clarify the delivery date of a tax decision. The taxpayer argued that the authority failed to establish objective truth by focusing only on delivery details rather than the overall evidence. The court ruled that such additional fact-finding does not constitute a gross violation of the objective truth principle unless the taxpayer's objections are obviously groundless.
Legislator headnote
AI generatedArt. 122 Ordynacji podatkowej; Art. 57 ust. 2 ustawy o Naczelnym Sądzie Administracyjnym: The removal of an administrative organ's decision to make additional findings on the factual date of delivery cannot be classified as a gross violation of the objective truth principle if the party's objections are not obviously groundless.