The tax notification-decision was justified by sales below cost, the incompleteness of primary documents, the uncertainty of tax expenses due to lack of reality of business transactions in the wholesale trade of the client, according to fiscal officials point of view.
The tax inspectorate’s conclusions were refuted before the court.
We proved that household appliances were sold through hypermarkets with a profit of 10-70% within the client’s main activity. 
None of the transactions between the client and counterparty is commodity-less operation.