The Directorate General of Taxation (Respondent) corrected PT KCI export sales by IDR 3,560,140,448.00, citing data discrepancies in the DGT-DGCE data exchange portal. The Respondent believed certain Export Declaration (PEB) documents had not been reported in the July 2014 VAT Return, despite the audit being based solely on portal screenshots without verifying physical PEB documents.
The legal conflict intensified when PT KCI asserted that all export values had been reported, though document reference numbers differed between internal systems and the DGT's. The Respondent maintained the portal data's validity under Article 1 point 11 of the VAT Law. Conversely, the Taxpayer argued that systemic synchronization errors should not negate the material fact that exports occurred and were cumulatively reported.
The Board of Judges stated that the data exchange portal serves as a monitoring tool but is not a singular substitute for competent evidence under Article 29 paragraph (2) of the KUP Law. Since the Respondent could not produce the physical PEBs claimed to be unreported, the Board ruled the correction lacked a strong and legally valid evidentiary basis.
This decision implies that digital data validation by tax authorities must still be supported by authentic physical documents in court. PT KCI's victory in this post confirms that the burden of proof for systemic-administrative corrections lies with the tax authority if the Taxpayer can demonstrate material reporting consistency.
In conclusion, DGT-DGCE portal data accuracy is not absolute without physical evidence verification. Taxpayers are advised to systematically archive PEBs and export service notes to counter automated data equalization challenges from tax authorities.
A Comprehensive Analysis and the Tax Court Decision on This Dispute Are Available Here
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