Bukti Bahwa Error pada Sistem e-Faktur Tidak Boleh Menghilangkan Hak Kredit Pajak Anda

Tax Lawsuit Analysis: PT. MAI and the Victory of Material Justice over e-Faktur System Glitches

The dispute originated when the Respondent made a positive correction of Input Tax amounting to IDR 6,567,992,771.00 for the June 2019 Tax Period of PT. MAI (formerly PT. HLI). The tax authority argued that pursuant to Article 9, paragraph (9) of the VAT Law, Input Tax not reported in the VAT Return cannot be credited if discovered during an audit. The Respondent categorized this value as a "new discovery" because it did not appear in the compensation column for VAT overpayment from the previous period in the 1st Amended June 2019 VAT Return.

The Conflict: Technical Glitches vs. The Right to Credit Input Tax

Court facts revealed that PT. MAI had correctly reported the overpayment in the May 2019 VAT Return. The issue arose when the company filed the 1st Amendment for May 2019 to adjust export values without changing the VAT amount. Systemically, the e-Faktur application disabled the compensation checkbox for the subsequent period, preventing the value from being automatically carried forward to June 2019. The Petitioner emphasized that this was purely a technical system glitch, not a deliberate failure to report.

Judicial Ruling: Substance Over Form and Administrative Fairness

In its consideration, the Board of Judges emphasized the principle of substance over form and legal justice. The Judges ruled that since the overpayment was substantively real and had been reported in its original period (May 2019), administrative failures caused by glitches in the Respondent's own e-Faktur system should not override the Taxpayer's constitutional right to credit Input Tax. The Judges stated that administrative systems should facilitate the fulfillment of rights and obligations, rather than becoming an obstacle to material truth.

A Comprehensive Analysis and the Tax Court Decision on This Dispute Are Available Here