Supreme Court dismisses appeal as statute of limitations issue exceeds scope of tax liability decision review.

The Supreme Court dismissed the cassation appeal regarding the statute of limitations for a third-party tax liability decision. The procedural scope was limited to verifying the legality of the Social Insurance Institution's decision on the manager's liability, not the expiration of the obligation itself. The court ruled that the statute of limitations question only arises during enforcement proceedings after the liability decision becomes final, thus falling outside the administrative appeal's subject matter.