Questione giuridica chiave
Whether the administrative law appeal was admissible against the federal appeal commission decision and against the tax administration decision
Decisione estratta
The appeal was admissible only against the decision of the federal appeal commission; it was inadmissible insofar as it sought annulment of the tax administration's prior decision because of the devolutive effect.
Motivazione estratta
The case still fell under the former VAT ordinance by virtue of the transitional rule, and the appeal met the formal conditions against the commission decision, but the earlier administrative decision was displaced by the later appeal decision.