Comentários ao Processo: 11516.001924/2002-18 do CARF
| Autor | Alexandre Pontieri |
Recorrente: Fazenda Nacional
Recorrido: Contribuinte
Ementa da Decisão recorrida: “EMBARGOS DE DECLARAÇÃO - Embargos acolhidos para sanar omissão e contradição. ARBITRAMENTO - FACTORING - O arbitramento deve ser mantido quando se verifica omissão de receita sem comprovação de origem e o contribuinte não tem escrituração regular, mas em se verificando a operação de factoring, a base imponível deve ser reduzida de acordo com os índices de lucratividade da atividade de factoring, os quais devem ser aplicados sobre os montantes dos depósitos bancários, nos casos em que este é o motivo do lançamento. Em se...
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