Questione giuridica chiave
Whether the tax office could declare the objection against the back-tax assessments inadmissible as late
Decisione estratta
No. In the circumstances, the taxpayers had to be allowed into the objection proceedings and the objection had to be dealt with on the merits.
Motivazione estratta
The office's later reliance on a missed deadline contradicted the understanding reached at the objection hearing, where documents were to be supplied for review. This contradictory conduct breached good faith, which also binds the tax authority.