ARTICLE 132: CONTENT OF THE RESOLUTION

The resolution of the appeal will be based on the law and will examine each and every one of the grievances asserted by the appellant, having the faculties to invoke notorious facts; but in the case of grievances that refer to the substance of the controversial issue, unless one of them is well based, must examine them all before submitting into the analysis of those that cause the violation of formal requirements or procedural defects.

The authority may correct the errors that it warns in the citation of the precepts that are considered violated and examine as a whole the grievances, as well as the other reasoning of the appellant, in order to solve the question, but without changing the facts presented in the resource. Also, they may revoke administrative acts when notice a manifest illegality and the grievances are insufficient but must carefully state the reasons why it considered the illegal act and specify the scope of its resolution.

Administrative acts may not be revoked or modified in the part not challenged by the appellant.

The resolution will clearly state the acts that are modified and, if the modification is partial, the amount of the corresponding tax credit will be indicated. Likewise, said resolution must indicate the terms within which it can be challenged in the administrative contentious trial. When the reference is omitted in the resolution, the taxpayer will have twice the term established by the legal provisions to file the administrative contentious trial.