E 'legitimate inductive determination on the taxpayer's bank accounts even if it has not been previously requested. It' as decided by the Tax Section of the Court of Cassation (path n . 2026872008). In particular, the ermine, the ruling stated that "the activities of financial administration, having an administrative nature, is guided by the principle of contradiction, so that Article. 51, second paragraph, no 2 of the said Presidential Decree, in providing for the convening of the party exercising the company with an invitation to provide the same data, news and clarification of the operations recorded in the bank accounts, the Administration gives a discretionary and not mandatory, with the further consequence that the failure to exercise the option, no changes to the statutory presumption rebuttable presumption that the activity report on the banking transactions by the taxpayer, that are subject therefore the burden of proof to the contrary by way of litigation, pursuant to art. 32 of Legislative Decree no. December 31, 1992, No 546 "and that" in terms of assessment of taxes on income, is a legitimate use by the financial authorities of the movements of bank accounts in readiness for the taxpayer, even without first consulting the person concerned on the subject of banking verification and verbalization the related statements, there being no rule stipulates the obligation of the Office of the prior meeting of the taxpayer. "
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