تصحيح الإجراء المعيب ضمانة لحماية الحق الموضوعي في سير المنازعة الضريبية

الملخص EN

The effectiveness of procedural rule in the field of tax litigation is measured by its procedural sanction in the case of incompatibility of the legal model.

So, the importance of the procedural penalty lies in the protection of the procedural rules from the defects in the form and subject matter.

However, the imposition of these effects on the procedural penalty prevents the protection of the substantive rights in question from the parties to the dispute charged with tax as the weak party in the dispute.

Therefore , the legislator created legislative means, including correcting the defective procedure as one of the guarantees to the conflicting parties to correct procedural errors in order to achieve a balance between procedural rule and protection of substantive rights .