In the case when taxpayers are dissatisfied with the tax assessment disposition and file an administrative litigation after the recheck application, they may amend or add claim to the illegal tax assessment disposition before an administrative appeal decision is made by the administrative appeal review committee or the administrative litigation oral arguments on matters of fact being concluded, and the agency with jurisdiction of administrative appeal or administrative court shall take this into consideration; the same will be done when the agency with jurisdiction of administrative appeal or administrative court discovers that tax assessment disposition is illegal ex officio.
In the case of the preceding paragraph, the tax collection authorities shall file an allegation and state specifically and clearly the opinion of the amended or added claim.
Administrative courts shall produce evidence to verify taxpayers’ tax payable and assess the amount within the range of taxpayers’ challenges, except for complex cases which are difficult to settle.
The cases which are filed as an administrative litigation by taxpayers due to their dissatisfaction with the tax assessment dispositions, rechecks, or administrative appeal decisions, of which the tax assessment dispositions, rechecks, or administrative appeal decisions are revoked or amended by the court because of illegality after the implementation of this Act, and the tax payable has not been determined over 15 years after the date on which the revoked or amended judgment is made by the court, may not be assessed again.
The preceding paragraph may apply to belated surcharge, interests, delinquent reporting surcharges, and fines.