Comentários ao Processo: 10980.005957/2005-22 do CARF
| Autor | Alexandre Pontieri |
Recorrente: Contribuinte
Recorrida: Fazenda Nacional
Ementa da Decisão recorrida: “IMPOSTO SOBRE A RENDA DE PESSOA JURÍDICA - IRPJ ANO-CALENDÁRIO: 2000, 2001, 2002 Ementa: ARBITRAMENTO DO LUCRO - FALTA DE APRESENTAÇÃO DE LIVROS E DOCUMENTOS - A falta de apresentação de livros e documentos à autoridade fiscal é motivo suficiente para que se arbitre o lucro da pessoa jurídica. DECADÊNCIA - IRPJ - Tratando-se de infração qualificada, o direito de constituir o crédito tributário pode ser exercido no lapso de cinco anos contados a partir do primeiro dia do exercício seguinte àquele em que o lançamento poderia ser efetuado. OMISSÃO DE RECEITAS - DEPÓSITOS/CRÉDITOS BANCÁRIOS NÃO CONTABILIZADOS - Evidencia omissão de receitas a existência de valores creditados em conta de depósito ou de investimento mantida junto a instituição financeira, em relação aos quais o titular, de direito ou de fato, pessoa física ou jurídica, regularmente intimado, não comprove, mediante documentação hábil e idônea, a origem dos recursos utilizados nessas operações. MULTA QUALIFICADA - Cabe a aplicação da multa qualificada, quando restar comprovado que o...
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