A specialized inter-district administrative court in the Pavlodar Region has overturned a tax authority notice issued following an audit, citing multiple procedural violations, according to infohub.kz.
The unscheduled thematic tax audit was triggered by the plaintiff's mutual settlements with an individual entrepreneur, against whom the tax authority had previously imposed restrictions on issuing electronic invoices.
During the trial, numerous procedural flaws were identified. Specifically, the court found that the administrative hearing and witness testimony procedures were conducted by an improper government body, the protocol lacked mandatory signatures, and the scope of the tax audit was insufficiently defined.
Additionally, the court noted violations in the conduct and documentation of the tax inspection, inconsistencies between copies of the inspection report, differing tax assessment amounts listed in the notice, and failure to comply with the statutory deadline for completing the audit as set by the Tax Code.
The court concluded that these procedural irregularities could have affected the legality of the administrative act. Consequently, the tax audit notice was declared unlawful and annulled.
The court granted the administrative claim. The territorial state revenue body was ordered to reimburse the plaintiff's court costs, including the state fee. The ruling has entered into force.