Questão jurídica principal
Whether the appeal against the remand judgment was admissible as a separately challengeable interim decision.
Decisão extraída
The remand decision was separately appealable because it could force the ESTV into an erroneous discretionary assessment causing irreparable legal harm.
Fundamentação extraída
The remand required more than technical implementation and could not later be effectively challenged; Art. 93(1)(a) BGG was satisfied.