Questão jurídica principal
Whether a loss allegedly incurred in 1998 could be offset against 1999 profit after the 1998 discretionary assessment became final.
Decisão extraída
No. The final 1998 assessment bound the tax authorities; without a revision ground, the company could not reopen the 1998 result in these proceedings or offset a loss inconsistent with that final assessment.
Fundamentação extraída
A legally final assessment is binding even if made by discretionary estimation. The company should have challenged the 1998 assessment by objection and submitted its accounts then. Economic capacity principles do not override the legal force of an unchallenged, materially incorrect assessment.