Also applicable to the holder of the entity demande his nullity via the contentious-administrative proceeding, provided that the demand is brought thereunder within three years of notified the resolution issued by the Board or tribunal. () The published standard is healthy because it raises unnecessary limitation that had the tax court to exercise its power to review their own actions, and ending by generating the apparent conflict that is its hierarchical lower which execute the also apparent control of the resolutions in the last administrative instance, via the contentious-administrative proceeding. Furthermore, this standard, in a manner consistent with the Act No. 27584, strictly allows the tax court to extend review of their actions with the use of the prejudicial effect process; and being also congruent with what was expressed in the previous item, only in the event that the tax court does not exercise that power, tax administrations may resort to article 157 of the TUO of the tax code. Finally, should sign the Decree legislative No. 1067 has modified article 17 of law No. 27584 and your numeral 2 to the letter says: 2.
when the Act empowers administrative entities initiate the contentious-administrative proceeding in accordance with the second paragraph of article 11 of this law, the term shall be laid down in the General Administrative Procedure Act, except statutory provision that establishes different period. () Thus safeguarding any possibility of contradiction within the necessary deadlines for the start of the process of prejudicial effect in charge of the tax court or the contentious process initiated by the tax authorities under article 157. of the TUO of the tax code, very healthy situation. IV. conclusions taking care that the administrative acts enjoy a presumption of legitimacy, when they become not declared void ex officio in the same administrative headquarters, is imperative that public administration entities turn court via the contentious-administrative proceeding, that doctrine is known as process of prejudicial effect.
when the Act empowers administrative entities initiate the contentious-administrative proceeding in accordance with the second paragraph of article 11 of this law, the term shall be laid down in the General Administrative Procedure Act, except statutory provision that establishes different period. () Thus safeguarding any possibility of contradiction within the necessary deadlines for the start of the process of prejudicial effect in charge of the tax court or the contentious process initiated by the tax authorities under article 157. of the TUO of the tax code, very healthy situation. IV. conclusions taking care that the administrative acts enjoy a presumption of legitimacy, when they become not declared void ex officio in the same administrative headquarters, is imperative that public administration entities turn court via the contentious-administrative proceeding, that doctrine is known as process of prejudicial effect.
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