Comentários ao Processo: 16327.003896/2003-97 do CARF
| Autor | Alexandre Pontieri |
Recorrente: Fazenda Nacional
Recorrido: Contribuinte
Ementa da Decisão recorrida: “Assunto: Imposto sobre a Renda de Pessoa Jurídica - IRPJ - Anos-calendário: 1998 e 1999 AUTOS DE INFRAÇÃO. NULIDADE. Os fatos apontados pela recorrente não determinam nulidade dos Autos de Infração, mormente aqueles ligados a conversão de moeda, quando a falha apontada já fora corrigida na decisão recorrida. DOS MÉTODOS DE APURAÇÃO DOS PREÇOS DE TRANSFERÊNCIA E DOS EVENTUAIS AJUSTES. Mesmo quando a fiscalizada não aponta o método de apuração dos preços de transferência, os auditores fiscais encarregados da verificação deverão utilizar o método mais favorável ao contribuinte ou demonstrar a impossibilidade de aplicação de outros métodos passíveis de utilização nas operações praticadas. MATÉRIAS-PRIMAS E OUTROS INSUMOS. MÉTODO PIC. EXIGÊNCIA DE SIMILARIDADE. Na apuração de ajustes efetuados pelo método PIC (Preços...
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