Comentários ao Processo nº 13807.004926/2001-20 do CARF
| Autor | Pontieri |
“IRPJ/CSLL - DECADÊNCIA - Em Consonância com a jurisprudência deste colegiado, decai o lançamento com o decurso do prazo de cinco anos contados do fato gerador.
ARBITRAMENTO DE LUCRO - (ANO-CALENDÁRIO DE 1997) A inexatidão dos dados registrados nos Livros e Documentos da escrituração contábil, por ocasião da autuação, justifica o arbitramento do lucro calculado sobre os valores das receitas da Empresa.
INCONSTITUCIONALIDADE - "O Primeiro Conselho de Contribuintes não é competente para se pronunciar...
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