Taz authority according with a result of on-site tax audit considered unfounded that the taxpayer included in expenses for 2010 costs related to 2008-2009 and mae claims in amount of more 106 mln. rub.
The court of first instance agreed with facts of the specialists National Law Company "Mitra", which represented interests of the client, that taxpayer has the right to recalculate the tax base for income tax for the period in which errors or distortions relating to prior periods are revealed, if they led to an excessive payment of tax (p. 1 Art. 54 the Tax Code of the Russian Federation).