<![CDATA[This study focuses on analyzing the resolution of intertemporal regulatory conflicts in four Tax Court decisions (August 19, 2024) concerning PT HT. The core of the dispute analyzed is the tax authority’s error in using PMK 31/2014 as the basis for correcting the VAT Assessment Notice (SKPKB) for the September–December 2019 period, even though that regulation had been revoked by PMK 18/2021 as of February 17, 2021. This study is a normative legal research employing a legislative, case-based, and conceptual approach. The main finding of this study is that the temporal conflict was resolved through Article 110(1) and (2) of PMK 18/2021 (as provisions governing implementation), rather than merely through the principle of lex posterior. The Tax Court granted the petition due to a fundamental procedural defect in the legal basis but simultaneously ordered a substantive re-examination based on the principle of substantive truth (Article 76 of the Tax Court Law). This hybrid ruling serves to balance legal certainty and substantive justice (Radbruch’s dialectic), anchored in the doctrine of defects in administrative decisions (KTUN). The mention of “substance over form” in the ruling is merely nominal, as the panel of judges interpreted it as prioritizing substantive truth.]]>
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