Comentários ao Processo: 10768.017907/98-31 do CARF
| Autor | Alexandre Pontieri |
Recorrente: Fazenda Nacional
Recorrido: Contribuinte
Ementa da Decisão recorrida: “IRPJ – DESPESAS DESNECESSÁRIAS - DEDUTIBILIDADE. Para as despesas financeiras serem consideradas dedutíveis, na apuração do lucro operacional, devem ser necessárias para a realização das transações ou operações exigidas pela atividade da empresa (art. 242 combinado com o art. 318 do RIR/94). IRPJ – PREJUÍZO NA VENDA DE AÇÕES. O prejuízo apurado encontra-se dentro do limite previsto no art. 336 do RIR/94. Não está provado nos autos de que a operação efetivamente não ocorreu ou que os preços de mercado não foram os de mercado. IRPJ - MÚTUO ENTRE EMPRESAS LIGADAS - Se o fisco não prova que o empréstimo fora...
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