LATEST CHECKED POSITION

Where the record stands

The 2019 decision is the latest decision located for this exact process. Any later special appeal, collection or related proceedings remain unchecked. Sources: [1]

Response & qualifying evidence

The taxpayer disputed the valuation theory. The reviewed ruling is favorable to the taxpayer. Sources: [1]

What remains unestablished

An upheld fine, a fraud finding, proof that every import was compliant, or closure of all separate customs proceedings.

CLOSE READING / 02 / A favorable outcome

What changed when the customs assessment was cancelled?

Follow the reviewed assessment to its favorable disposition, without turning it into a global clearance.

  1. 01 / The amount in the record

    R$25,468,380.32

    The reviewed assessment. Not an upheld fine or an amount paid.

    S009 · assessment, p.2
  2. 02 / The favorable decision

    Cancellation left in place

    On 19 June 2019, CARF unanimously rejected the official appeal for lack of proof of under-invoicing.

    S009 · disposition, p.1; reasoning, pp.12–16
  3. 03 / The review boundary

    Not a global clearance

    The 2019 decision is the latest decision located for this exact process. Any later special appeal, collection or related proceedings remain unchecked.

    Read what this decision does not establish
One assessment, one reviewed disposition: CARF 10611.720885/2017-89 · Acórdão 3201-005.482. The favorable outcome stays attached to the amount. These stages refer to the same source, not independent corroboration.

The chronology

  1. Official appeal denied unanimously.

    S009 p.1 Sources: [1]

The next verification

Check later appeals and any distinct forfeiture proceedings; keep favorable outcome in every derivative.

Entity attribution

Named entity established within cited record; ownership and responsibility assessed separately. Sources: [1]

THE SOURCE FILE

Sources for this article

1 linked sources. Cited records, reporting, responses and background are labelled below. A source establishes only what its review scope supports; separate proceedings and repeated coverage are not additional findings.

  1. SOURCE 1 / Cited record / S009

    CARF Acórdão 3201-005.482

    Conselho Administrativo de Recursos Fiscais · 2019-06-19 decision · Original language: Portuguese

    Published by Conselho Administrativo de Recursos Fiscais.

    Used for / context: pp.1–2 and 12–16; process 10611.720885/2017-89

    Review limits: Selected extracted sections read: disposition p.1, assessment p.2, reasoning pp.12–16. Image retrieval failed; full document not reviewed. AI-assisted translation.

    Open source · Source register

    Return to: Chronology 2019-06-19 · Article summary · Current position · Response · Entity attribution

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