The Power of a Typo: PT PAS Wins Lawsuit to Revise Tax Court Decision Due to Clerical Errors

Tax Dispute: Verdict Rectification, Formal Defects, and Legal Certainty for PT Pegasus Air Services

Legal certainty in tax litigation depends entirely on the accuracy of the court's verdict, specifically in identifying the object of the dispute correctly. Tax Court Decision Number PUTP1-007781.99/2024/PP-R1 reinforces that a clerical error regarding the number and date of a decree is a formal defect that can be corrected through a lawsuit mechanism to ensure the execution of the decision and legal certainty for the Taxpayer.

Core Conflict: Clerical Error in Decree Identity

The case originated when PT Pegasus Air Services (PAS) identified inconsistencies in the verdict of Decision Number PUT-007781.99/2024/PP/M.XVIIIB Year 2025. The previous Panel of Judges cited decree number KEP-00103/KEB/WPJ.07/2023 dated January 16, 2023, whereas the correct object was KEP-00103/KEB/WPJ.07/2022 dated January 14, 2022. This one-digit year error was critical, as it hindered administrative follow-up by the Defendant (DGT) and the submission of a Judicial Review to the Supreme Court.

Judicial Resolution: Exercising Authority under Article 80 Paragraph (1) Letter f

In response, PT PAS formally requested a revision. The XVIIIB Panel of the Tax Court acted swiftly by reviewing the Deputy Registrar's memorandum and case files. In its legal consideration, the Panel admitted to an unintentional printing error. Based on Article 80 paragraph (1) letter f of the Tax Court Law, the Panel exercised its authority to grant the request and align the verdict with the actual facts presented during the trial.

Final Resolution and Implications: Prioritizing Substantive Justice

The final resolution of this dispute was the full granting of the rectification lawsuit. The Panel ordered the previous verdict to be revised with the correct decree identity. This decision demonstrates that the Tax Court prioritizes substantive justice over administrative rigidity, ensuring that Taxpayers' rights are not compromised by technical writing errors.

The implication of this ruling serves as a vital lesson for Taxpayers to always conduct thorough proofreading of received court decisions. Precision in verifying numbers, dates, and values within the verdict is crucial. Should similar errors occur, proactively filing a petition for correction through the lawsuit mechanism is a valid and effective legal remedy in Indonesia.

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