Acórdão nº 00175/12.6BEPNF de Tribunal Central Administrativo Norte, 07 de Maio de 2020
Data | 07 Maio 2020 |
Órgão | http://vlex.com/desc1/1998_01 |
Acordam em conferência na Secção de Contencioso Tributário do Tribunal Central Administrativo Norte: 1. RELATÓRIO A Recorrente, O., LDA.
, pessoa coletiva n.º (…), interpôs recurso da sentença prolatada, pelo Tribunal Administrativo e Fiscal de Penafiel, que julgou improcedente a impugnação judicial visando as liquidações adicionais de IVA e respetivos juros compensatórios, referente ao ano de 2005, que perfazem no montante global de € 84.250,20.
A Recorrente não se conformou com a decisão tendo interposto o presente recurso formulou nas respetivas alegações as seguintes conclusões que se reproduzem: “(…) CONCLUSÕES DA DISCORDÂNCIA NA DECISÃO SOBRE A MATÉRIA DE FACTO E NAS RAZÕES DE DIREITO, EM SEDE DE SENTENÇA IMPUGNAÇÃO DA MATÉRIA DE FACTO DOS CONCRETOS PONTOS DE FACTO CONSIDERADOS INCORRECTAMENTE JULGADOS MATÉRIA DADA COMO PROVADA E QUE NO ENTENDER DA RECORRENTE MERECE SER DADA COMO NÃO PROVADA 1.
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A impugnante foi sujeita a um procedimento de inspeção externo, parcial, aos exercícios de 2005 e 2006 que está documentado no RIT, cujo teor, consta de fls. 208 a 217 verso, cujo teor aqui se dá por reproduzido. [Na parte de procedimento de inspeção interno] C) O procedimento de inspeção foi motivado pela existência de indícios da utilização de faturas que não correspondem a operações reais [O procedimento de inspeção foi motivado pela existência do operador/contribuinte N. Lda. actuar á margem da lei] E) Nos exercícios de 2005 e 2006 a impugnante tinha registado na sua...
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