Sala, Noro e Associati, with a team led by partnerStefano Noro, successfully secured the annulment by the Lombardy Regional Tax Commission of a majortax assessment noticeissued to a taxpayer regarding presumed income from the holding of capital abroad. The most innovative aspect of the decision is its clarification that, since this was a partial assessment, there was no obligation for a prior hearing, and for this very reason, the notice served on the taxpayer could not justify any further extension of the deadlines. The Court therefore ruled out the combination of the doubling of deadlines and the COVID extension, establishing a principle of great importance for the protection of legal certainty and taxpayer rights.
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