Disquisitions about the deadline to request the contradictory expert pricing after having previously reserved

Abstract

Contradictory Expert Pricing (CEP) and its reservation are configured as basic mechanisms aimed the effective and legitimate defense of the interests of taxpayers in the process of checking values.

The deadline for applying effectively the CEP after having previously reserved is a subject that has been judicial interpretations involving procedural distortions. The argument is raised, one more time, following the unfortunate concept of «finality in administrative proceedings» that has been wrongly interpreted as the date of notification of the agreement to settle the action or claim brought against the checking of values, whereas the orthodox interpretation would have been the consecration of the «finality in administrative proceedings» is delayed until the deadline to attend the next instance (whether administrative or even judicial already).

The significance of the date on which the firmly is consecrate determine the «dies a quo» for applying effectively the CEP (with its relevant suspense effects).