Question juridique clé
Whether the respondent's late objection against the provisional replacement tax assessment could be treated as a valid basis for revision.
Solution extraite
No. The objection was filed after the statutory deadline, and no request for restoration of the time limit was made; the assessment had entered into force.
Motifs extraits
Revision under Art. 40 WPEV is exceptional and unavailable where the party could and should have raised the point in the ordinary procedure. The service days were not newly discovered, not officially recorded for the tax authority, and no procedural violation was shown.