...
Witness, Mr. Cohen: Ledger, the bookkeeping is a multi-year ledger for that matter, the inputs I claim in a particular year are invoices that I had in that year, if I receive for that purpose in January 2018 an invoice with the date 2017 I claim it for the purpose of appealing taxes in 2018 On the invoice it appears to me in 2017 so you can't make this correlation it's inaccurate...
Adv. Feierstein: So if I look at additional years and we do it together because no, if I go through more years, then we will be given an indication? In other words, wait a minute, I'll continue, how do you explain that in 2018 the input tax was deducted in the sum of NIS 490,000 when the total transactions of the company amounted to NIS 389,000, how do you explain that?
Witness, Mr. Cohen: Again, in some things here there are 80 pages here, there may be, as I said, shifting between the years, again because I explained to you the source of the data of the two data of the table that you are putting out to the table that is here, the source is different, first of all, second thing, Mrs. Remnik did the work here in retrospect, 12-13 years back, she may not have been 100% accurate" (p. 13, S. 25 - p. 14, S. 5 of the minutes of the evidentiary hearing).
- When, in all the years of assessment, inputs for medical expenses unrelated to hospitalization were deducted at a higher rate than the transaction tax paid in those years, the explanation of the appellant's accountant cannot stand. This is not a negligible inaccuracy, and if it was indeed a matter of "shifting", the differences should have been balanced in the end.
- Afterwards, when he was asked again about the difference, he changed his answer and argued as follows:
"Adv. Feierstein: ... Let's say the input tax that the company deducted, and in retrospect it says it shouldn't have been cleaned, OK, it shouldn't have been issued for it, it's a medical service that doesn't qualify for an exemption, and therefore it should have been chained to the medical tourist with a transaction tax, is it likely that it will be lower than this input tax?