Review of Case Law of the Cassation Court for Administrative Cases

I. Resolution of the Cassation Court for Administrative Cases of the Republic of Kazakhstan No. 6003-25-00-4k/2283 dated 21 January 2026 

Challenging the Tax Authority’s Actions in Issuing an Order for a Tax Audit

LLP “ASYL enbek” (hereinafter – the “Claimant”) filed an administrative claim against the Tax Department  of Almaty region (hereinafter – the “Respondent” or the “Department”) seeking recognition as unlawful and cancellation of Order No. 192 dated 13 November 2024 on the appointment of an unscheduled thematic tax audit.

By the decision of the Specialized Interdistrict Administrative Court of Almaty Region dated 13 February 2025, the claim was satisfied and the Order was declared unlawful and annulled. By the appellate ruling dated 8 July 2025, the first-instance decision was upheld. By the Resolution of the Cassation Court dated 21 January 2026, the judicial acts of the lower courts were left unchanged and the cassation appeal of the Department was dismissed. 

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