The Supreme Court, by judgment no. 13584/2017, confirmed the deadline of 60 days to oppose non-notified tax acts.

In the present case, the taxpayer turned to Equitalia after having learned about a mortgage inscription based on the files he had ever recieved, and after having applied for the role extract and verified the (now prescribed) petition, he decided to oppose, but after six months from the request for the extracts of the role.

By basing his claim on the failure to notify, having known the imposition of taxation after a mere casual examination of the mortgage inscription, so in a non-ritual way, the judges, with the judgment in question, established the legitimacy of his opposition, but it has also confirmed, on the other hand, the peremptory nature of the deadline of 60 days from the delivery of the role extract to the taxpayer (which is the term ex art. 21 d.lgs. 546/92).