ARTICLE 95: OBJECT, PROCEDURE AND RESOLUTION OF THE APPEAL FOR REVOCATION

The appeal referred to in this chapter is intended to revoke, modify or confirm the contested resolution and the rulings that are issued will contain the fixation of the claimed act, the legal basis on which it is based and the points of resolution.

The appeal for revocation (LA: Art. 203) will be processed and resolved in accordance with the provisions of the Federal Fiscal Code (Código Fiscal de la Federación), its depletion being necessary for the provenance of the trial before the Federal Court of Fiscal and Administrative Justice (Tribunal Federal de Justicia Fiscal y Administrativa).

The resolutions that are issued when resolving the appeal for revocation or those that have it by not filed, may be challenged before the Federal Tax and Administrative Court (Tribunal Federal de Fiscal y Administrativa), by trial that will be substantiated in accordance with the provisions of the Federal Fiscal Code (Código Fiscal de la Federación) and the Organic Law of the Federal Court of Fiscal and Administrative Justice (Ley Orgánica del Tribunal Federal de Justicia Fiscal y Administrativa).

Resolutions not appealed within the scope established in the Federal Fiscal Code (Código Fiscal de la Federación) shall be deemed permitted and may not be challenged before the Federal Court of Fiscal and Administrative Justice (Tribunal Federal de Justicia Fiscal y Administrativa).