Background

The tax authority estimated the net profits of a company for the years from 1981 to 1985 and the company objected to these estimates. The case was referred to the commission of tax appeal which decided to decrease the estimates. The company filed a case to appeal this decision.

The court upheld the decision made by the commission of tax appeal.

The company appealed the ruling before the court of appeal. The court upheld the appealed ruling.

Decision

The company appealed the ruling before the court of cassation and said in its grounds of appeal that the ruling had erred in the application of law and that the commission included the revenues which had resulted from transactions with another company in the estimate although the company had never dealt with this company. The company said that the court dismissed this defence based on the argument that the commission did not consider it and the company could not introduce it before the court.