Questão jurídica principal
Whether the complaint against the Federal Tax Administration's decision was admissible before the Federal Supreme Court.
Decisão extraída
The appeal was admissible only against the Federal Administrative Court judgment; it was inadmissible to the extent directed at the substituted ESTV objection decision.
Fundamentação extraída
The lower court judgment replaced the objection decision by virtue of the devolutive effect; only the judgment could be challenged.