Key legal question
Whether the 4 July 2005 tax assessment was void because the authority refused the pillar 3a deduction without first asking for the certificate.
Extracted holding
No. The defect alleged by the taxpayers was not a ground for nullity; it was at most a matter for ordinary remedies.
Extracted reasoning
Nullity requires a particularly serious and obvious defect, usually a grave procedural error or lack of jurisdiction. Here the competent authority issued a formal assessment in the proper procedure. The omission complained of did not threaten legal certainty to the extent required for nullity, especially since the assessment could have been challenged by timely objection.