Евгений Шелест
stokkete / Depositphotos.com
Соответствующий вывод содержится в постановлении Арбитражного суда Волго-Вятского округа от 28 января 2019 г. № Ф01-6742/18 по делу № А28-8096/2017. В решении о проведении выездной налоговой проверки и в справке о ее окончании инспекция указала период проверки юрлица с 1 января 2013 г. по 31 декабря 2014 г. Однако уже после окончания проверки налоговики направили обществу письмо, в котором сообщалось о допущенной технической опечатке (ошибке). А именно, выездная проверка планировалась за период с 1 января 2012 г. по 31 декабря 2014 г. За этот период истребовались документы у налогоплательщика. По результатам проверки инспекция пришла к выводу, что юрлицо утратило право на применение УСН в третьем квартале 2012 года.
Суды указали, что инспекция нарушила положения п. 2 ст. 89 Налогового кодекса. Напомним, что согласно этой норме в решении о проведении выездной проверки должен быть указан, в том числе, проверяемый период. Однако в решение о проведении проверки изменения не внесены. Суды отметили, что указание периода проверки является существенным условием ее проведения. Данное условие определяет права и обязанности налогового органа и налогоплательщика в ходе проверки. Изменение проверяемого периода путем исправления опечатки недопустимо, тем более после окончания проверки. Следовательно, 2012 год не подлежал проверке.
Зависит ли срок проведения выездной налоговой проверки от даты ознакомления проверяемого лица с решением о назначении проверки? Узнайте из материала «Решение о проведении выездной налоговой проверки» в «Энциклопедии решений. Налоги и взносы» интернет-версии системы ГАРАНТ. Получите полный доступ на 3 дня бесплатно!
По результатам рассмотрения дела кассационный суд оставил в силе постановление апелляционного суда в силе, а кассационную жалобу инспекции – без удовлетворения.
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Автор предоставляет подробные сведения и контекст, что помогает читателям лучше понять обсуждаемую тему.
Эта статья действительно отличная! Она предоставляет обширную информацию и очень хорошо структурирована. Я узнал много нового и интересного. Спасибо автору за такую информативную работу!
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Статья предлагает объективный обзор исследований, проведенных в данной области. Необходимая информация представлена четко и доступно, что позволяет читателю оценить все аспекты рассматриваемой проблемы.
I’d like to find out more? I’d love to find out more details.
Статья предлагает глубокий анализ темы и рассматривает ее со всех сторон.
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Статья содержит информацию, подкрепленную надежными источниками, представленную без предвзятости.
Автор представляет сложные понятия в понятной и доступной форме, что erleichtert das Verständnis.
Great article and right to the point. I don’t know if this is truly the best place to ask but do you guys have any ideea where to hire some professional writers? Thank you 🙂
Читателям предоставляется возможность самостоятельно интерпретировать представленную информацию.
Это позволяет читателям самостоятельно сформировать свое мнение.
Я хотел бы поблагодарить автора этой статьи за его основательное исследование и глубокий анализ. Он представил информацию с обширной перспективой и помог мне увидеть рассматриваемую тему с новой стороны. Очень впечатляюще!
Автор использовал разнообразные источники, чтобы подкрепить свои утверждения.
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Автор предоставляет подробные сведения и контекст, что помогает читателям лучше понять обсуждаемую тему.
Статья содержит достаточно информации для того, чтобы читатель мог сделать собственные выводы.
Автор статьи представляет информацию в объективной манере, избегая субъективных оценок.
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Мне понравилась объективность и сбалансированность в подаче материала в статье.
Статья предлагает читателю возможность самостоятельно сформировать свое мнение на основе представленных аргументов.
Статья помогает читателю разобраться в сложной проблеме, предлагая разные подходы к ее решению.
Автор не вмешивается в читателей, а предоставляет им возможность самостоятельно оценить представленную информацию.
Автор представляет сложные темы в понятной и доступной форме для широкой аудитории.
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Я прочитал эту статью с огромным интересом! Автор умело объединил факты, статистику и персональные истории, что делает ее настоящей находкой. Я получил много новых знаний и вдохновения. Браво!
Я оцениваю объективность и непредвзятость автора в представлении информации.
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Мне понравился объективный подход автора, который не пытается убедить читателя в своей точке зрения.
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Эта статья действительно отличная! Она предоставляет обширную информацию и очень хорошо структурирована. Я узнал много нового и интересного. Спасибо автору за такую информативную работу!
Я не могу не отметить стиль и ясность изложения в этой статье. Автор использовал простой и понятный язык, что помогло мне легко усвоить материал. Огромное спасибо за такой доступный подход!
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Мне понравился объективный и непредвзятый подход автора к теме.
Я прочитал эту статью с большим удовольствием! Она написана ясно и доступно, несмотря на сложность темы. Большое спасибо автору за то, что делает сложные понятия понятными для всех.
Информационная статья предлагает взвешенный подход к обсуждаемой теме, аргументируя свои выводы доказательствами и статистикой.
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Читателям предоставляется возможность самостоятельно интерпретировать представленную информацию.
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Статья предлагает широкий обзор событий и фактов, связанных с обсуждаемой темой.
Я оцениваю объективный подход автора и его стремление представить полную картину проблемы.
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Автор статьи предоставляет разностороннюю информацию, основанную на различных источниках.
Автор не высказывает собственных предпочтений, что позволяет читателям самостоятельно сформировать свое мнение.
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Аргументы в статье представлены объективно и нейтрально.
Эта статья является примером качественного исследования и профессионализма. Автор предоставил нам широкий обзор темы и представил информацию с точки зрения эксперта. Очень важный вклад в популяризацию знаний!
Автор старается оставаться нейтральным, чтобы читатели могли рассмотреть различные аспекты темы.
Я оцениваю степень детализации информации в статье, которая позволяет получить полное представление о проблеме.
When someone writes an article he/she maintains the thought of a user in his/her mind that how a user can know it. Thus that’s why this post is outstdanding. Thanks!
Надеюсь, что эти комментарии добавят ещё больше позитива и поддержки к информационной статье!
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Это помогает читателям получить полную картину и сформировать собственное мнение на основе предоставленных фактов.
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Статья предлагает объективный обзор исследований, проведенных в данной области. Необходимая информация представлена четко и доступно, что позволяет читателю оценить все аспекты рассматриваемой проблемы.
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Автор подходит к этому вопросу с нейтральной позицией, предоставляя достаточно информации для обсуждения.
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