Comentários ao Processo: 11543.000709/00-31 do CARF
| Autor | Alexandre Pontieri |
Embargante: Fazenda Nacional
Embargado: Contribuinte
Ementa da Decisão recorrida: “NORMAS GERAIS DE DIREITO TRIBUTÁRIO. Período de apuração: 01/01/1989 a 01/03/1997. RESTITUIÇÃO. PRESCRIÇÃO. Para os pedidos de restituição protocolizados antes da vigência da Lei Complementar nº 118/2005, o prazo prescricional é de conformidade com a tese cognominada de cinco mais cinco. As decisões do Superior Tribunal de Justiça, em sede recursos repetitivos, por força do art. 62-A do Regimento Interno do CARF, devem ser...
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