Background

Two traders filed a case before the First Instance Tax Court against the tax office because the appeal committee had compelled them to pay their tax and an additional amount in Article 34(3) of Egypt Law No. 157/1981 for not submitting the declaration on time.

The court reduced the estimated amount.

Both parties filed an appeal and the court confirmed the appealed ruling.

Decision

The defendant filed an appeal in cassation on the grounds that the appealed ruling had violated the law and erred in its application and interpretation because it had limited the obligation to pay the additional amount as a penalty for the defendant's failure to submit the declaration in time to the financier holding the commercial records, when this penalty was applicable to the financier who did not also hold them.