Questione giuridica chiave
Whether a permit for tax-privileged electricity withdrawal can be granted retroactively.
Decisione estratta
A retroactive permit is generally not possible because the already-taxed electricity has already been consumed and the permit can no longer be used for it.
Motivazione estratta
The permit serves a prospective function; once electricity has been taken at the regular tax rate, the legal effect sought by retroactive authorization cannot be achieved.