<![CDATA[This study aims to analyze the validity of the rejection of an application for the reduction or cancellation of administrative sanctions under Article 36 paragraph (1) letter a of the General Provisions and Tax Procedures Law (UU KUP), as well as to analyze the legal reasoning of the Panel of Judges in Tax Court Decision Number PUT-004622.99/2025/PP/M.XIA (2025). This research employs a normative-juridical method utilizing statutory, conceptual, and case-based approaches. The analysis focuses on the discretionary authority of the Directorate General of Taxes in evaluating taxpayer applications and the *ratio decidendi* of the Panel of Judges in reviewing the rejection decision. The findings indicate that the rejection of the application by the Directorate General of Taxes lacked substantive validity; the reasoning was overly formalistic, relying on administrative and financial parameters that were not directly relevant to the substance of the tax invoice issuance issue. The Panel of Judges held that issuing a tax invoice prior to payment and the delivery of goods in Crude Palm Oil (CPO) transactions could not be classified as a delay, as it aligned with regulations regarding the timing of tax invoice issuance and the Plaintiff's transaction practices. Through systematic and teleological interpretation, the Panel corrected the tax authority's erroneous application of the law and cancelled administrative sanctions amounting to IDR 111,162,500.00. The decision affirms that the discretion exercised by the Directorate General of Taxes is not absolute authority; it remains subject to the law, General Principles of Good Governance (AUPB), and judicial review to ensure legal certainty and protection for taxpayers.]]>
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