Comentários ao Processo nº 13708.000059/94-63 do CARF
| Autor | Pontieri |
Deve ser mantida a glosa dos valores apropriados como custos em relação aos quais o sujeito passivo não apresentou documentação comprobatória.
CSLL. IRRF.
Tratando-se de lançamentos lavrados como decorrência dos mesmos fatos que implicaram na exigência do IRPJ, aplica-se àqueles o resultado do julgamento referente a este.
IRPJ E CSLL. ARBITRAMENTO DO LUCRO. GLOSA DE PARTE SUBSTANCIAL DOS CUSTOS. DESCLASSIFICAÇÃO DA ESCRITA CONTÁBIL/FISCAL -
Efetuada pela Fiscalização a glosa de parte significativa dos custos auferidos pelo contribuinte vis a vis os valores declarados, incumbe-lhe desclassificar a escrita contábil/fiscal apresentada por ser esta evidentemente inservível para apuração do lucro real. Nesses casos, deve a...
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