Supreme Court held tax audit renewal rules apply, not tax ordinance, due to statutory hierarchy.

The Supreme Court quashed the Naczelnego Sądu Administracyjnego's decision regarding a tax audit renewal request. The taxpayer argued the Tax Ordinance governed the procedure, but the General Tax Inspector insisted on the Tax Audit Control Act. The Court ruled that the specific Tax Audit Control Act prevails over the general Tax Ordinance for audit matters, preventing the application of the latter's renewal provisions.