Key legal question
Whether the Federal Supreme Court could entertain the request to annul the first-instance ESTI order directly.
Extracted holding
The direct request to annul the ESTI order was inadmissible because of the devolutive effect of the appeal; the order was only deemed implicitly challenged.
Extracted reasoning
Once the Federal Administrative Court had ruled, the lower administrative order could no longer be independently attacked in the appeal to the Federal Supreme Court.