Questão jurídica principal
Whether the tax office could declare the objection against the back-tax assessments inadmissible as late
Decisão extraída
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.
Fundamentação extraída
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.