Comentários ao Processo: 13808.001547/98-66 do CARF
| Autor | Alexandre Pontieri |
Recorrente Fazenda Nacional
Recorrido: Contribuinte
Ementa da Decisão recorrida: “ASSUNTO: OUTROS TRIBUTOS OU CONTRIBUIÇÕES. Exercício: 1994 NORMAS GERAIS DE DIREITO TRIBUTÁRIO - DECADÊNCIA – Sendo o Imposto sobre a Renda de Pessoa Jurídica - IRPJ, tributo sujeito ao lançamento pela modalidade homologação, o início da contagem do prazo é o da ocorrência do fato gerador do tributo, salvo se comprovada a ocorrência de dolo, fraude ou simulação. PRECLUSÃO - Nos termos das normas aplicáveis ao processo administrativo fiscal, na impugnação deve ser apresentada toda a matéria de defesa, ficando prejudicada a análise de questões que sejam trazidas tão somente no recurso. Matéria preclusa. Não conhecimento. Não se conhece de matéria, somente...
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