Tax debt extinguished by payment does not render tax appeal inadmissible despite statute of limitations expiry.

The Supreme Court partially allowed the taxpayer's appeal against a tax authority decision to dismiss the case due to the statute of limitations. The taxpayer had paid the tax debt before the five-year limitation period expired, which extinguished the obligation under tax law. The court ruled that extinction via payment is distinct from extinction via limitation and does not deprive the taxpayer of the right to appeal the administrative decision.