Jurisprudencia de la CSJN: Impuesto a las ganancias. Quebrantos. Carga de la prueba. Facultades de Verificación y Fiscalización. Art. 33 de la ley 11683 (t.o. vigente).

SÍNTESIS.- En el presente caso, nuestro máximo Tribunal sostuvo, con cita de antecedentes jurisprudenciales propios, que la carga de la prueba de la existencia y cuantía de los quebrantos corresponde a quien pretenda el reconocimiento de dicho crédito, sin que nada permita suponer que en tales supuestos el Fisco deba abdicar de las facultades de control que le han sido conferidas. Con relación a esto último la Corte sostuvo que la actora no esgrimió ninguna razón de peso para modificar el criterio establecido en el art. 33 de la ley 11683 (t.o. vigente) en cuanto a que el valor probatorio de las registraciones contables se encuentra sujeto al respaldo de los comprobantes correspondientes y a la fe que éstos merezcan.

“Volkswagen Argentina S.A. y otros  c/ AFIP DGI- resols. 66, 67 y 68/98 s/Dirección General Impositiva”, C.S.J.N., 3/5/2016.

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Sumario realizado por la Dra. Carolina Petraglia

 

32 comentarios de “Jurisprudencia de la CSJN: Impuesto a las ganancias. Quebrantos. Carga de la prueba. Facultades de Verificación y Fiscalización. Art. 33 de la ley 11683 (t.o. vigente).

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