Questione giuridica chiave
Whether the taxpayers could seek revision based on newly discovered incorrect salary-certificate deductions for occupational pension contributions.
Decisione estratta
The revised application had to be admitted because the incorrect deduction figures were a material new fact not reasonably discoverable in the ordinary proceedings.
Motivazione estratta
The taxpayers would have had to recalculate the pension deductions monthly to detect the error; this was not a matter of easy verification. Employees were entitled to rely on the employer to issue correct salary certificates, so no lack of due diligence could be imputed to them.