First, I doubt whether this is indeed an extension of the façade, since such an argument was argued by the appellant in the framework of the motion to amend the assessment – see, for example, section 4.19 of the motion to amend the assessment. Moreover, this is a legal argument, which derives from documents and facts that are not in dispute, when in any case the respondent was given full opportunity to address these arguments in the summaries of his arguments in writing, and he did so and at length.
- In addition, the argument of widening the façade raised by the appellant in paragraph 21 of chapter B(2)(1) of the summaries of the reply on its behalf is rejected, regarding the claim of asymmetry between a request to amend an assessment by a taxpayer versus an amendment initiated by the respondent, as well as the determination of criteria for sparse examination and approval in exceptional and rare cases only of requests to amend self-assessments submitted by the taxpayer. Indeed, these arguments are not found as written and worded in the amended repentance. The argument raised by the respondent in the amended reply regarding the appellant's failure to meet the condition Article 85 The law is detailed in sections 17-22 thereof, and in my opinion it is possible to find at least the beginning of an argument that requests to amend a self-assessment on behalf of the taxpayer should be examined differently (see, for example, section 17 of the amended reply).
In any case, in this case, too, this is a legal argument and the appellant addressed, at great length, all of the respondent's arguments in his summaries on this matter in the framework of the summaries of the reply on her behalf.
- Moreover, and taking into account the legal issue in dispute in these appeals and its considerable broad ramifications, I am of the opinion that in the framework of our decision in these appeals, consideration must be given to the entirety of the parties' arguments, in order for the judgment to be comprehensive and complete and will not require further litigation, at least not within the framework of the Appeals Committee.
- From here, to the hearing and decision of the appeals.
However, before we go into the factual basis and the arguments of the parties, there is room to give background regarding the "Buyer's Price" project.