Questione giuridica chiave
Whether the revision request was filed within the statutory 90-day period after discovery of the revision ground.
Decisione estratta
The period started at the earliest on receipt of the November 2016 notice of discontinuance of the criminal investigation; the request was therefore timely.
Motivazione estratta
The earlier information about foreign criminal proceedings and a mutual legal assistance matter did not yet provide a usable revision ground. The discontinuance notice gave the first confirmation of the taxpayer's account, and the November 2016 and February 2017 filings fell within 90 days.