Questão jurídica principal
Whether the objection against the withholding tax refund decision was filed within time or could be treated as timely.
Decisão extraída
The objection was late; the original decision had been properly served and the appellant reacted only after the 30-day period had expired.
Fundamentação extraída
The appellant’s own statements showed receipt and awareness of the decision. The later filing of 21 December 2001 could therefore only be treated as an untimely objection.