Questão jurídica principal
Whether the appeal could also seek annulment of the tax authority's objection decision and a declaratory ruling of exemption.
Decisão extraída
The challenge to the objection decision was inadmissible because it was replaced by the Federal Administrative Court judgment; the declaratory request was also inadmissible because a performance decision on the tax liability for the relevant period was available.
Fundamentação extraída
Only the lower court judgment is the proper object of appeal under the devolutive effect, and in VAT matters a standalone declaratory action is excluded where the tax liability can be decided in a merits decision for a concrete period.