New binding precedent rules out the existence of controversy if amended tax returns were filed during a tax inspection.

Supreme Court Decision No. 03158-2022-LIMA, issued on August 18, 2023, has stated that there is no matter in dispute if a taxpayer filed amended tax returns during a tax audit to incorporate the observations made by the inspector, generating the issuance of closing resolutions with no adjustments. As a result, the former is precluded from subsequently challenge those resolutions with a view to reversing the effects of the observations made by the tax administration during the tax inspection.