«GCBA c/ M. ROYO S.A.», Cámara de Apelaciones Contencioso, Administrativo y Tributario C.A.B.A., 3/09/14

SUMARIO.- Si la diferencia de Alumbrado, Barrido y Limpieza, detectada por la Administración, se origina en la redeterminación de la obligación tributaria como consecuencia de la modificación del avalúo de los inmuebles (que constituye la base imponible del tributo), no puede sostenerse que sea –al menos desde el punto de vista dogmático– una obligación con distinta causa que la del tributo liquidado conforme el avalúo anterior.
Esquemáticamente, la obligación tributaria es una sola y tiene causa en la realización del hecho imponible (cfr., respecto de la naturaleza jurídica de la contribución de alumbrado, barrido y limpieza, territorial, de pavimentos y aceras y adicional ley Nº23.514 como un “conglomerado de tributos” y las matizaciones que dicha caracterización implica respecto de la afirmación anterior, el voto del juez Corti «in re» “Central Puerto S.A. c/ GCBA s/ repetición (art. 457 CCAyT)”, expte. Nº3.848, del 28/09/06). La diferencia de Alumbrado, Barrido y Limpieza es, sencillamente, eso, la diferencia entre los pagos realizados por el contribuyente –conforme un determinado avalúo– y los que –a criterio del Fisco local, materializado en la liquidación de la diferencia de Alumbrado, Barrido y Limpieza conforme el nuevo avalúo– debía haber pagado (siempre que la diferencia fuera en más a favor de la Administración fiscal), teniendo en cuenta la medida real de la obligación tributaria.

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28 comentarios de “«GCBA c/ M. ROYO S.A.», Cámara de Apelaciones Contencioso, Administrativo y Tributario C.A.B.A., 3/09/14

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  5. I am going to machines this review in the direction of Two patterns of people today: current Zune home owners who are taking into consideration an improve, and folks hoping in direction of make a decision concerning a Zune and an iPod. (There are other gamers worthy of contemplating out there, together with the Sony Walkman X, nevertheless I be expecting this gives your self plenty of facts in the direction of produce an conscious determination of the Zune vs avid gamers other than the iPod line as effectively.)

  6. This is turning out to be a bit further more subjective, however I a great deal desire the Zune Sector. The interface is vibrant, is made up of further aptitude, and some great options which includes ‘Mixview’ that permit you all of a sudden check out identical albums, music, or other end users similar in the direction of what you happen to be listening in the direction of. Clicking on a person of people will centre upon that product, and one more mounted of «neighbors» will occur into watch, allowing for yourself toward navigate in close proximity to looking into as a result of very similar artists, tunes, or buyers. Talking of users, the Zune «Social» is far too exceptional enjoyable, enabling yourself obtain others with shared preferences and turning into friends with them. By yourself then can pay attention in direction of a playlist crafted based upon an amalgamation of what all your good friends are listening toward, which is also interesting. Those apprehensive with privateness will be relieved in direction of understand on your own can steer clear of the public against seeing your specific listening routines if you therefore just take.

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  8. This is taking a little bit further subjective, but I much favor the Zune Market. The interface is vibrant, consists of even more aptitude, and some great options including ‘Mixview’ that permit you quickly perspective very similar albums, songs, or other end users equivalent toward what you are listening towards. Clicking upon one of these will middle on that product or service, and yet another mounted of «neighbors» will appear into view, making it possible for on your own in the direction of navigate near exploring by equivalent artists, songs, or end users. Speaking of end users, the Zune «Social» is much too Terrific exciting, allowing on your own uncover some others with shared tastes and getting to be pals with them. By yourself then can hear towards a playlist constructed based mostly on an amalgamation of what all your buddies are listening toward, which is furthermore interesting. Those people nervous with privateness will be relieved toward comprehend oneself can stop the community in opposition to watching your individual listening patterns if you thus determine.

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  10. The Zune concentrates on staying a Portable Media Player. Not a internet browser. Not a recreation machine. Possibly inside the future it’s going to do even improved inside those people areas, however for at present it truly is a remarkable path toward arrange and pay attention in direction of your music and flicks, and is without having peer inside of that regard. The iPod’s advantages are its internet browsing and programs. If those people good even further compelling, possibly it is your great preference.

  11. Palms down, Apple’s application keep wins as a result of a mile. It really is a huge choice of all sorts of programs vs a very sad quantity of a handful for Zune. Microsoft consists of programs, especially within just the realm of games, yet I’m not absolutely sure I might will need toward wager on the upcoming if this element is vital to you. The iPod is a significantly better option within that circumstance.

  12. In between me and my spouse we have owned added MP3 gamers around the many years than I can count, like Sansas, iRivers, iPods (classic & touch), the Ibiza Rhapsody, and so forth. But, the ultimate couple several years I have resolved down towards one line of players. Why? Due to the fact I was pleased to examine how well-designed and fun in the direction of retain the services of the underappreciated (and widely mocked) Zunes are.

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  14. Arms down, Apple’s application store wins by means of a mile. It is a huge final decision of all varieties of apps vs a in its place not happy conclusion of a handful for Zune. Microsoft includes Ideas, particularly within just the realm of games, nevertheless I am not confident I would require towards guess upon the future if this element is crucial to you. The iPod is a much far better selection inside that circumstance.

  15. The contemporary Zune browser is surprisingly constructive, but not as Fantastic as the iPod’s. It works nicely, nonetheless isn’t as fast as Safari, and consists of a clunkier interface. If you from time to time method upon working with the internet browser that’s not an issue, yet if you happen to be building in direction of browse the net alot towards your PMP then the iPod’s greater screen and improved browser might be significant.

  16. Sorry for the substantial analyze, nevertheless I’m fairly loving the new Zune, and expect this, as effectively as the excellent assessments some other Those people comprise created, will assist yourself determine if it can be the specifically decision for yourself.

  17. The refreshing Zune browser is astonishingly favourable, yet not as Terrific as the iPod’s. It functions very well, nevertheless isn’t really as quick as Safari, and is made up of a clunkier interface. If yourself sometimes program upon taking the internet browser that is not an issue, nonetheless if you’re coming up with towards read through the website alot in opposition to your PMP then the iPod’s larger show and much better browser may possibly be important.

  18. Apple at present has Rhapsody as an application, which is a best commence, nevertheless it is at this time hampered by the incapacity towards store regionally on your iPod, and contains a dismal 64kbps bit price. If this changes, then it will fairly negate this benefit for the Zune, yet the Ten songs per thirty day period will nevertheless be a significant furthermore within Zune Pass’ like.

  19. Zune and iPod: Most americans evaluate the Zune towards the Contact, yet at the time seeing how skinny and shockingly tiny and gentle it is, I look at it in the direction of be a very exceptional hybrid that combines qualities of both the Touch and the Nano. It is really Quite colorful and attractive OLED exhibit is slightly smaller than the contact screen, still the player by itself feels fairly a little bit smaller and lighter. It weighs concerning 2/3 as considerably, and is appreciably scaled-down within just width and top, while remaining exactly a hair thicker.

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