Евгений Шелест
FlashDevelop / Depositphotos.com
Довод общества о том, что в случае отмены вышестоящим налоговым органом решений налоговой инспекции, оно не может быть привлечено к налоговой ответственности, признан ошибочным (постановление Арбитражного суда Московского округа от 18 декабря 2018 г. № А40 – 16571/2018).
Налоговая инспекция направила юрлицу требование о представлении документов по взаимоотношениям с контрагентом. В связи с тем, что документы были не представлены, налоговый орган вынес решение о привлечении организации к ответственности за совершение налогового правонарушения по п. 2 ст. 126 Налогового кодекса в виде штрафа 10 тыс. руб. На данное решение общество подало жалобу, по результатам рассмотрения которой инспекция вынесла новое решение и уменьшила штраф в 8 раз. Но, посчитав свои права нарушенными, юрлицо обратилось с жалобой в Управление на оба решения нижестоящего налогового органа. В ходе рассмотрения жалобы Управление ФНС России по субъекту Федерации выявило нарушения процедуры привлечения к налоговой ответственности, допущенные налоговой инспекцией.
Есть ли ограничения по количеству требований о представлении документов (информации), которые могут направляться налоговым органом? Узнайте из материала «Истребование налоговым органом документов и информации у третьих лиц (встречные проверки)» в «Энциклопедии решений. Налоги и взносы» интернет-версии системы ГАРАНТ. Получите полный доступ на 3 дня бесплатно!
А именно, юрлицу не обеспечена возможность участия в их рассмотрении. На основании рассмотренных материалов и документов, Управление отменило решения инспекции и приняло новое решение о привлечении лица к ответственности в виде штрафа 10 тыс. руб. (п. 2 ст. 126, п. 3, абз.2 п. 5 ст. 140 НК РФ). Суды трех инстанций согласились с Управлением в том, что его решение не привело к дополнительным взысканиям, кроме предусмотренных п. 2 ст. 126 НК РФ и не ухудшило положение общества. Таким образом, права и законные интересы не могут быть признаны нарушенными.
По результатам рассмотрения дела кассационный суд оставил без изменения решение суда первой инстанции и постановление суда апелляционной инстанции, а кассационную жалобу – без удовлетворения.
Russian
Why is it I always really feel like you do?
I got this site from my friend who informed me regarding this web site and now this time I am visiting this website
and reading very informative posts here.
It is really a nice and useful piece of info. I am glad that you shared this useful info with us. Please keep us informed like this. Thanks for sharing.
I simply wanted to thank you very much yet again. I’m not certain the things that I would have carried out without the type of creative concepts revealed by you over this field. It became the depressing matter in my circumstances, but considering the very professional form you dealt with the issue forced me to jump for delight. I am thankful for the guidance as well as pray you really know what an amazing job you are always accomplishing teaching other individuals with the aid of your website. I’m certain you haven’t encountered any of us.
obviously like your website but you have to check the spelling on several of your posts. A number of them are rife with spelling issues and I find it very bothersome to tell the truth nevertheless I’ll surely come back again.
I have been exploring for a bit for any high-quality articles or blog posts on this sort of area . Exploring in Yahoo I at last stumbled upon this site. Reading this information So i am happy to convey that I have a very good uncanny feeling I discovered exactly what I needed. I most certainly will make certain to do not forget this web site and give it a glance regularly.
Hello! I just would like to give a huge thumbs up for the great info you have here on this post. I will be coming back to your blog for more soon.
Thanks for sharing superb informations. Your web site is very cool. I am impressed by the details that you have on this site. It reveals how nicely you understand this subject. Bookmarked this website page, will come back for extra articles. You, my friend, ROCK! I found simply the info I already searched everywhere and just could not come across. What a perfect web site.
As soon as I found this site I went on reddit to share some of the love with them.
After research a few of the blog posts in your website now, and I really like your way of blogging. I bookmarked it to my bookmark website listing and shall be checking back soon. Pls take a look at my web site as well and let me know what you think.
I really like your writing style, good information, regards for posting :D. «All words are pegs to hang ideas on.» by Henry Ward Beecher.
certainly like your web site but you need to check the spelling on quite a few of your posts. Several of them are rife with spelling issues and I find it very troublesome to tell the truth nevertheless I will surely come again again.
I am glad to be a visitor of this everlasting weblog! , thankyou for this rare information! .
Wow! This can be one particular of the most useful blogs We have ever arrive across on this subject. Actually Great. I’m also a specialist in this topic therefore I can understand your hard work.
Hello my loved one! I wish to say that this post is awesome, great written and come with almost all vital infos. I would like to see more posts like this .
You got a very fantastic website, Glad I found it through yahoo.
I haven’t checked in here for a while because I thought it was getting boring, but the last few posts are great quality so I guess I will add you back to my everyday bloglist. You deserve it my friend 🙂
I have recently started a website, the information you offer on this website has helped me greatly. Thanks for all of your time & work.
Hey, you used to write excellent, but the last few posts have been kinda boringK I miss your tremendous writings. Past several posts are just a bit out of track! come on!
As a Newbie, I am always browsing online for articles that can aid me. Thank you
Wow, superb blog layout! How lengthy have you been running a blog for? you make running a blog glance easy. The full glance of your web site is excellent, as neatly as the content!
I¦ll right away seize your rss as I can’t in finding your e-mail subscription hyperlink or newsletter service. Do you’ve any? Kindly let me recognize so that I could subscribe. Thanks.
I think other web-site proprietors should take this site as an model, very clean and wonderful user genial style and design, let alone the content. You are an expert in this topic!
This really answered my problem, thank you!
It¦s really a cool and useful piece of info. I am happy that you just shared this useful information with us. Please stay us up to date like this. Thanks for sharing.
I was reading through some of your articles on this internet site and I conceive this site is really instructive! Keep putting up.
Thanks a bunch for sharing this with all of us you actually know what you’re talking about! Bookmarked. Kindly also visit my website =). We could have a link exchange arrangement between us!
Have you ever considered writing an e-book or guest authoring on other blogs? I have a blog based on the same topics you discuss and would love to have you share some stories/information. I know my readers would value your work. If you are even remotely interested, feel free to shoot me an e mail.
Hi my friend! I wish to say that this article is awesome, nice written and include approximately all significant infos. I would like to see more posts like this.
Great awesome issues here. I am very satisfied to peer your post. Thank you a lot and i’m having a look forward to touch you. Will you please drop me a mail?
What Is Puravive? Before we delve into the various facets of the supplement, let’s start with the most important
Loving the information on this website , you have done outstanding job on the posts.
I’m really enjoying the design and layout of your site. It’s a very easy on the eyes which makes it much more enjoyable for me to come here and visit more often. Did you hire out a developer to create your theme? Exceptional work!
Would you be inquisitive about exchanging links?
The very root of your writing whilst appearing reasonable initially, did not sit well with me after some time. Somewhere within the paragraphs you actually managed to make me a believer unfortunately only for a while. I still have got a problem with your jumps in assumptions and one would do well to fill in those breaks. In the event that you actually can accomplish that, I will definitely be amazed.
Tonic Greens, a natural health supplement, is designed to enhance immune function.
Dentitox Pro is marketed as a natural oral health supplement designed to support dental health and hygiene.
Some times its a pain in the ass to read what website owners wrote but this website is rattling user friendly! .
I precisely had to thank you very much once again. I do not know the things I could possibly have implemented without the entire points shown by you directly on my subject. It truly was a real troublesome circumstance in my opinion, but spending time with a expert technique you solved that forced me to leap for gladness. I am just happier for your advice and as well , hope you realize what a great job you are always putting in educating most people thru your webpage. Most probably you’ve never come across any of us.
I’ve been absent for a while, but now I remember why I used to love this web site. Thanks, I will try and check back more often. How frequently you update your web site?
What Is LeanBiome? LeanBiome, a new weight loss solution, includes beneficial strains of gut bacteria that work fast for weight loss.
Very interesting details you have observed, regards for putting up.
You really make it seem really easy along with your presentation but I in finding this topic to be really something that I think I might never understand. It seems too complicated and very vast for me. I’m taking a look ahead for your subsequent post, I?¦ll try to get the dangle of it!
I like this website very much so much great info .
Great line up. We will be linking to this great article on our site. Keep up the good writing.
I wanted to thank you for this great read!! I definitely enjoying every little bit of it I have you bookmarked to check out new stuff you post…
My spouse and i got really fortunate when Edward managed to round up his research through your precious recommendations he gained through the web pages. It’s not at all simplistic to just continually be releasing helpful tips which often a number of people may have been trying to sell. So we recognize we need the writer to be grateful to for that. The entire explanations you have made, the simple site menu, the relationships you help instill — it is most spectacular, and it is letting our son in addition to the family believe that this topic is cool, and that is particularly pressing. Thanks for all the pieces!
whoah this blog is magnificent i love reading your articles. Keep up the great work! You know, a lot of people are hunting around for this info, you could aid them greatly.
The next time I read a blog, I hope that it doesnt disappoint me as much as this one. I mean, I know it was my choice to read, but I actually thought youd have something interesting to say. All I hear is a bunch of whining about something that you could fix if you werent too busy looking for attention.
Wow! This can be one particular of the most helpful blogs We’ve ever arrive across on this subject. Basically Excellent. I am also an expert in this topic so I can understand your effort.
Whats Going down i am new to this, I stumbled upon this I have found It positively helpful and it has helped me out loads. I am hoping to contribute & aid other users like its helped me. Great job.
I like the helpful info you provide in your articles. I will bookmark your weblog and check again here regularly. I am quite sure I’ll learn a lot of new stuff right here! Best of luck for the next!
hello!,I like your writing very so much! percentage we keep in touch extra approximately your post on AOL? I require an expert on this space to unravel my problem. May be that’s you! Taking a look forward to see you.
Hiya very cool site!! Guy .. Excellent .. Wonderful .. I’ll bookmark your site and take the feeds additionallyKI am happy to find a lot of useful information here within the publish, we’d like develop more strategies on this regard, thanks for sharing. . . . . .
Thanks for the sensible critique. Me and my neighbor were just preparing to do some research on this. We got a grab a book from our local library but I think I learned more clear from this post. I’m very glad to see such magnificent information being shared freely out there.
I simply could not depart your site prior to suggesting that I extremely enjoyed the standard info a person provide in your visitors? Is going to be again incessantly to check up on new posts.
FitSpresso: What Is It?FitSpresso is a natural weight loss aid designed for individuals dealing with stubborn weight gain. It is made using only science-backed natural ingredients.
I am not really great with English but I come up this really easy to translate.
You have noted very interesting points! ps nice internet site.
What Is LeanBiome? LeanBiome is a natural dietary supplement that promotes healthy weight loss.
Some genuinely superb blog posts on this web site, thankyou for contribution.
Magnificent site. Plenty of useful info here. I am sending it to several friends ans additionally sharing in delicious. And obviously, thanks on your sweat!
My brother recommended I may like this web site. He used to be entirely right. This post actually made my day. You can not believe just how much time I had spent for this info! Thanks!
I am extremely inspired with your writing abilities and also with the structure in your weblog. Is that this a paid theme or did you customize it yourself? Anyway stay up the nice quality writing, it’s uncommon to see a nice weblog like this one nowadays..
I like this site very much so much good info .
Great post, I think blog owners should larn a lot from this web site its real user pleasant.