Questão jurídica principal
Whether the appeal against the Federal Administrative Court's remand decision was admissible as a final or interim decision.
Decisão extraída
The remand decision was an interim decision, not a final decision, because the authority retained discretion on remand.
Fundamentação extraída
The lower court's ruling did not end the proceedings; the tax authority still had to determine the refund amount and could impose conditions, so the decision was not purely executory.