Questione giuridica chiave
Whether a VAT estimation notice issued after a control is itself a decision triggering the 30-day objection period.
Decisione estratta
A post-audit estimation notice is not, as such, a decision; it precedes the contentious phase and does not automatically start the objection deadline.
Motivazione estratta
Text, system, history and purpose of the VAT Act distinguish estimation notices from decisions; the Act reserves decisions for cases where they are necessary for tax collection or where the taxpayer disputes the assessment or payment is concretely threatened.