2024-01-26 | DOF 5715313

Added

Notice 500-05-2023-26077 Communicating List of Taxpayers Who Challenged Presumption Notices and Had Them Annulled

The Central Administration of Strategic Taxation publishes a list of 20 taxpayers whose final resolutions regarding the non-existence of operations were annulled by administrative or judicial bodies after the taxpayers filed defense mechanisms. The document details the specific legal challenges, the rulings that declared the original tax notices null and void, and the effective dates of these annulments for each entity. This action formally removes the legal effects of the presumption notices issued under Article 69-B of the Federal Tax Code for the listed contributors.

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DOF: 26/01/2024

OFFICE 500-05-2023-26077 through which a list of taxpayers who promoted some means of defense against the presumption office referred to in the first paragraph of Article 69-B of the Federal Tax Code or against the resolution referred to in the fourth paragraph of the aforementioned article is communicated, and once resolved, the jurisdictional or administrative body left the referred act without effects.

At the margin, a seal with the National Coat of Arms, which says: United Mexican States.- TREASURY.- Ministry of

Treasury and Public Credit.- Tax Administration Service.- General Administration of Federal Fiscal Audit

Central Administration of Strategic Taxation.

Office:

500-05-2023-26077

Subject:

Communication of list of taxpayers who promoted some means of defense against the presumption office referred to in Article 69-B first paragraph of the Federal Tax Code (CFF) or against the resolution referred to in the fourth paragraph of the aforementioned article and once resolved, the jurisdictional or administrative body left the referred act without effects.

This Central Administration of Strategic Taxation, attached to the General Administration of Federal Fiscal Audit, of the Tax Administration Service, based on what is provided in articles 16, first paragraph of the Political Constitution of the United Mexican States; 1, 7, fractions VII, XII and XVIII and 8, fraction III of the Law of the Tax Administration Service, published in the Official Gazette of the Federation on December 15, 1995, reformed by Decree published in the same Official Gazette on June 12, 2003; 1, 2, first paragraphs, section B, fraction III, subsection e) and second, 5, first paragraph, 13, fraction VI, 23, section E, fraction I, in relation to article 22 first paragraphs, fraction VIII, and last, numeral 5 of the Internal Regulations of the Tax Administration Service, published in the Official Gazette of the Federation on August 24, 2015, in force from November 22, 2015, in accordance with what is provided in the first paragraph of the First Transitory Article of said Regulations, and reformed by Decree by which various provisions of the Internal Regulations of the Ministry of Treasury and Public Credit and of the Internal Regulations of the Tax Administration Service are reformed and added, and by which the Internal Regulations of the National Customs Agency of Mexico are issued, published in the same official organ on December 21, 2021, in force from January 01, 2022, in accordance with what is provided in the First Transitory Article of said Decree; Article Third, fraction I, subsection a), of the Agreement by which various attributions are delegated to the Public Servants of the Tax Administration Service, published in the Official Gazette of the Federation on June 23, 2016, in force from July 23, 2016, in accordance with what is provided in the First Transitory Article of said Agreement; in articles 33, last paragraph, 63 and 69-B, paragraphs sixth of the Federal Tax Code, it communicates the following:

That to the taxpayers listed below, at their time, a Presumption Office of non-existence of operations backed by certain fiscal receipts that they issued was notified, in accordance with the first and second paragraphs of article 69-B of the Federal Tax Code, in relation to article 69 of its Regulations.

Following the procedure provided for in the aforementioned article 69-B of the Federal Tax Code, and in terms of the fourth paragraph of the aforementioned article, the aforementioned taxpayers were notified of the final resolution as indicated below:

Notification to the taxpayer of the FINAL RESOLUTION .

R.F.C. Name, denomination or corporate name of the Taxpayer Means of notification to the taxpayer Number and date of final resolution office Tax Box Authority's Court Personal Notification Date notified in Tax Box Date notification took effect Date of posting on the Authority's Court Date notification took effect Date of notification Date notification took effect

1 ASE1501279F0 AGATA SERVICIO, S.A. DE C.V. 500-51-00-05-02-2019-044451 dated November 26, 2019 03 December 2019 04 December 2019

2 ASE150130QK3 ASEPROVI, S.P.R. DE R.L. 500-70-00-04-01-2019-01718 dated February 15, 2019 07 March 2019 02 April 2019

3 CEP1105261S7 CIRCON ENERGIA PROFESIONAL, S.A. DE C.V. 500-54-00-02-01-2020-0557 dated March 30, 2020 03 April 2020 06 April 2020

4 CSG1201059UA COMERCIAL Y SERVICIOS GLOBALINC, S.A. DE C.V. 500-10-00-05-01-2020-42464 dated November 06, 2020 23 November 2020 16 December 2020

5 EEX060619ARA ESPINOZA EXPRESS, S.A. DE C.V. 500-10-00-05-00-2019-14147 dated March 19, 2019 21 March 2019 22 March 2019

6 HENS9203206M3 HERNANDEZ NICASIO SINDY 500-27-00-08-02-2021-02827 dated March 30, 2021 07 April 2021 08 April 2021

7 HIM121126SA5 HUMAN IMPROVING COMPANY, S.C. 500-05-2020-13771 dated July 17, 2020 17 July 2020 20 July 2020

8 LRU121205D33 LION RISORSE UMANE, S. DE R.L. DE C.V. 500-25-00-05-02-2019-8995 dated June 28, 2019 04 July 2019 05 July 2019

9 MGS140520TH3 MAR DEL GOLFO SUMINISTRO DE CONSTRUCCION, S.A. DE C.V. 500-19-00-05-01-2020-13306 dated December 10, 2020 16 December 2020 07 January 2021

10 NCA9804022P8 NYSSEN CONSULTORES ASOCIADOS, S.C. 500-39-00-06-02-2019-5492 dated May 23, 2019 30 May 2019 31 May 2019

11 OBA1701182Q7 OBANUAR, S.A. DE C.V. 500-42-00-08-03-2021-02855 dated July 15, 2021 02 August 2021 03 August 2021

12 PSM1407309KA PRESTADORA DE SERVICIOS MURATA, S.A. DE C.V. 500-74-06-03-01-2020-5671 dated December 10, 2020 15 December 2020 16 December 2020

13 PCR171223S34 PROYECTOS Y CONSTRUCCIONES ROXI, S.A. DE C.V. 500-44-00-00-00-2020-04101 dated June 29, 2020 07 July 2020 08 July 2020

14 RSI1602151T1 RH SERVICIOS INTELIGENTES, S. DE R.L. DE C.V. 500-05-2020-28635 dated November 13, 2020 19 November 2020 20 November 2020

15 SCI150216KB7 SCISPRO, S.A. DE C.V. 500-32-00-05-06-2020-3134 dated June 24, 2020 25 June 2020 26 June 2020

16 SSE1603045L5 SENESTE SERVICIOS, S.A. DE C.V. 500-69-00-06-02-2020-882 dated January 20, 2020 24 January 2020 27 January 2020

17 SCO150420DH8 STP CONSTRUCCIONES, S.A. DE C.V. 500-25-00-06-01-2020-14430 dated September 15, 2020 22 September 2020 23 September 2020

18 SPE150525HA6 SYS PROYECTOS EMPRESARIALES, S.A. DE C.V. 500-74-05-03-01-2019-7721 dated June 26, 2019 02 July 2019 03 July 2019

19 VPR140529V65 VINTAGE PROMOTIONS, S.A. DE C.V. 500-27-00-08-02-2020-03510 dated March 20, 2020 26 March 2020 27 March 2020

20 ZAVJ780709F9A ZAMAGO VARGAS JUAN CARLOS 500-16-00-00-00-2019-5540 dated April 09, 2019 22 April 2019 16 May 2019

Additional data of the taxpayers.

R.F.C. Name, denomination or corporate name of the Taxpayer Fiscal Address Preponderant Activity Reason for the Procedure

1 ASE1501279F0 AGATA SERVICIO, S.A. DE C.V. ZAPOPAN, JALISCO OTHER SUPPORT SERVICES FOR BUSINESSES Absence of assets Absence of personnel Lack of material capacity Lack of infrastructure

2 ASE150130QK3 ASEPROVI, S.P.R. DE R.L. TONALÁ, CHIAPAS BREEDING AND FATTENING OF CHICKENS FOR SALE OF THEIR MEAT Absence of assets Absence of personnel Lack of infrastructure Lack of material capacity

3 CEP1105261S7 CIRCON ENERGIA PROFESIONAL, S.A. DE C.V. ZAPOPAN, JALISCO MANUFACTURE OF OTHER MACHINERY AND EQUIPMENT FOR COMMERCE AND SERVICES Absence of assets Absence of personnel

4 CSG1201059UA COMERCIAL Y SERVICIOS GLOBALINC, S.A. DE C.V. ZAPOPAN, JALISCO INSTALLATION AND CONFIGURATION OF RACK, INSTALLATION AND CONFIGURATION OF ELECTRICAL CONTACT AND INSTALLATION AND CONFIGURATION OF CISCO, AMONG OTHERS Absence of assets Absence of personnel Lack of material capacity Lack of infrastructure

5 EEX060619ARA ESPINOZA EXPRESS, S.A. DE C.V. COMONDÚ, BAJA CALIFORNIA SUR OTHER LONG-DISTANCE AUTOTRANSPORT OF GENERAL CARGO Absence of assets Absence of personnel Lack of material capacity

6 HENS9203206M3 HERNANDEZ NICASIO SINDY TAXCO DE ALARCÓN, GUERRERO RETAIL TRADE OF WATCHES, FINE JEWELRY AND DECORATIVE ARTICLES OF PRECIOUS MATERIALS - WHOLESALE TRADE OF JEWELRY ARTICLES AND OTHER CLOTHING ACCESSORIES Absence of assets Absence of personnel Lack of material capacity

7 HIM121126SA5 HUMAN IMPROVING COMPANY, S.C. PUEBLA, PUEBLA CONSULTING SERVICES IN ADMINISTRATION, RETAIL TRADE OF NEW CLOTHING, REGIONAL SUITS, COSTUMES, FINE FURS, BRIDAL DRESSES, SCHOOL UNIFORMS, NOT MANUFACTURED WITH LEATHER AND SKIN, RENTAL OF OFFICES AND COMMERCIAL PREMISES. Absence of assets Absence of personnel

8 LRU121205D33 LION RISORSE UMANE, S. DE R.L. DE C.V. BENITO JUÁREZ, MEXICO CITY OTHER PROFESSIONAL, SCIENTIFIC AND TECHNICAL SERVICES Absence of personnel Lack of material capacity Lack of infrastructure

9 MGS140520TH3 MAR DEL GOLFO SUMINISTRO DE CONSTRUCCION, S.A. DE C.V. TUXTLA GUTIÉRREZ, CHIAPAS WHOLESALE TRADE OF OTHER CONSTRUCTION MATERIALS, EXCEPT WOOD, WHOLESALE TRADE OF CEMENT, BRICK AND GRAVEL Absence of assets Lack of material capacity Lack of infrastructure

10 NCA9804022P8 NYSSEN CONSULTORES ASOCIADOS, S.C. CUERNAVACA, MORELOS OTHER SUPPORT SERVICES FOR BUSINESSES Absence of assets Absence of personnel Lack of material capacity Lack of infrastructure

11 OBA1701182Q7 OBANUAR, S.A. DE C.V. GUADALUPE, NUEVO LEÓN CONSULTING SERVICES IN ADMINISTRATION, LAW FIRMS, OTHER SUPPORT SERVICES FOR BUSINESSES Absence of assets Absence of personnel Lack of infrastructure

12 PSM1407309KA PRESTADORA DE SERVICIOS MURATA, S.A. DE C.V. BENITO JUÁREZ, MEXICO CITY ADMINISTRATION CONSULTING SERVICES, RESEARCH AND PROTECTION SERVICES, WHOLESALE TRADE OF PHARMACEUTICAL PRODUCTS, WHOLESALE TRADE OF OTHER MACHINERY AND GENERAL USE EQUIPMENT, RESEARCH AND PROTECTION AND CUSTODY SERVICES, EXCEPT THROUGH MONITORING Absence of assets Absence of personnel Lack of infrastructure

13 PCR171223S34 PROYECTOS Y CONSTRUCCIONES ROXI, S.A. DE C.V. OAXACA, OAXACA DE JUAREZ OTHER CIVIL ENGINEERING CONSTRUCTIONS AND HEAVY WORK, WHOLESALE TRADE OF CEMENT BRICK AND GRAVEL, RENTAL OF MACHINERY FOR CONSTRUCTION, MINING AND FORESTRY ACTIVITIES. Absence of assets Absence of personnel Lack of material capacity Lack of infrastructure

14 RSI1602151T1 RH SERVICIOS INTELIGENTES S DE RL DE CV ÁLVARO OBREGÓN, MEXICO CITY BUSINESS ADMINISTRATION SERVICES AND PLACEMENT AGENCIES Absence of assets Absence of personnel

15 SCI150216KB7 SCISPRO, S.A. DE C.V. ZAPOPAN, JALISCO ADMINISTRATION CONSULTING SERVICES AND PERMANENT PERSONNEL SUPPLY Absence of assets Absence of personnel Lack of material capacity Lack of infrastructure

16 SSE1603045L5 SENESTE SERVICIOS, S.A. DE C.V. GUADALAJARA, JALISCO OTHER SCIENTIFIC AND TECHNICAL CONSULTING SERVICES, OTHER PROFESSIONAL SCIENTIFIC AND TECHNICAL SERVICES, ACCOUNTING AND AUDIT SERVICES Absence of assets Absence of personnel Lack of infrastructure

17 SCO150420DH8 STP CONSTRUCCIONES, S.A. DE C.V. LEÓN, GUANAJUATO CONSTRUCTION OF URBANIZATION WORKS Absence of assets Absence of personnel Lack of material capacity Lack of infrastructure

18 SPE150525HA6 SYS PROYECTOS EMPRESARIALES, S.A. DE C.V. ALVARO OBREGÓN, MEXICO CITY ADMINISTRATION CONSULTING SERVICES, OTHER PROFESSIONAL, SCIENTIFIC AND TECHNICAL SERVICES, WHOLESALE TRADE OF MACHINERY AND EQUIPMENT FOR OTHER SERVICES AND FOR COMMERCIAL ACTIVITIES, RECOGNITION AND SURFICIAL EXPLORATION AND OTHER SCIENTIFIC AND TECHNICAL CONSULTING SERVICES Absence of assets Absence of personnel

19 VPR140529V65 VINTAGE PROMOTIONS, S.A. DE C.V. MIGUEL HIDALGO, MEXICO CITY ADVERTISING AGENCIES, PUBLIC AFFAIRS AGENCIES, WHOLESALE TRADE OF TELECOMMUNICATIONS EQUIPMENT, WHOLESALE TRADE OF PHOTOGRAPHY AND CINEMATOGRAPHY. Absence of assets Absence of personnel Lack of material capacity

20 ZAVJ780709F9A ZAMAGO VARGAS JUAN CARLOS TORREÓN, COAHUILA DE ZARAGOZA OTHER SUPPORT SERVICES FOR BUSINESSES, OTHER INTERMEDIARIES OF WHOLESALE TRADE Absence of assets Absence of personnel Lack of infrastructure

Therefore, the name or corporate name of the taxpayers to whom the aforementioned resolutions were notified were added to the list referred to in the fourth paragraph of article 69-B of the Federal Tax Code, which was published in the Official Gazette of the Federation, as indicated below:

R.F.C. Name, denomination or corporate name of the Taxpayer Number and date of office containing in Global Definitive List Date of publication in the Official Gazette of the Federation

1 ASE1501279F0 AGATA SERVICIO, S.A. DE C.V. 500-05-2020-7673 dated February 14, 2020 06 March 2020

2 ASE150130QK3 ASEPROVI, S.P.R. DE R.L. 500-05-2019-18165 dated June 17, 2019 15 July 2019

3 CEP1105261S7 CIRCON ENERGIA PROFESIONAL, S.A. DE C.V. 500-05-2021-5054 dated February 09, 2021 22 February 2021

4 CSG1201059UA COMERCIAL Y SERVICIOS GLOBALINC, S.A. DE C.V. 500-05-2021-5205 dated March 03, 2021 22 March 2021

5 EEX060619ARA ESPINOZA EXPRESS, S.A. DE C.V. 500-05-2019-7413 dated May 15, 2019 06 June 2019

6 HENS9203206M3 HERNANDEZ NICASIO SINDY 500-05-2021-15535 dated July 14, 2021 19 August 2021

7 HIM121126SA5 HUMAN IMPROVING COMPANY, S.C. 500-05-2020-23449 dated September 25, 2020 12 October 2020

8 LRU121205D33 LION RISORSE UMANE, S. DE R.L. DE C.V. 500-05-2019-35774 dated October 17, 2019 08 November 2019

9 MGS140520TH3 MAR DEL GOLFO SUMINISTRO DE CONSTRUCCION, S.A. DE C.V. 500-05-2021-5303 dated March 04, 2021 18 March 2021

10 NCA9804022P8 NYSSEN CONSULTORES ASOCIADOS, S.C. 500-05-2019-27749 dated August 27, 2019 25 September 2019

11 OBA1701182Q7 OBANUAR, S.A. DE C.V. 500-05-2021-26102 dated October 15, 2021 04 November 2021

12 PSM1407309KA PRESTADORA DE SERVICIOS MURATA, S.A. DE C.V. 500-05-2021-5303 dated March 4, 2021 18 March 2021

13 PCR171223S34 PROYECTOS Y CONSTRUCCIONES ROXI, S.A. DE C.V. 500-05-2020-13925 dated August 26, 2020 17 September 2020

14 RSI1602151T1 RH SERVICIOS INTELIGENTES S DE RL DE CV

15 SCI150216KB7 SCISPRO, S.A. DE C.V. 500-05-2020-13925 dated August 26, 2020 17 September 2020

16 SSE1603045L5 SENESTE SERVICIOS, S.A. DE C.V. 500-05-2020-13568 dated May 13, 2020 29 June 2020

17 SCO150420DH8 STP CONSTRUCCIONES, S.A. DE C.V. 500-05-2021-5205 dated March 03, 2021 22 March 2021

18 SPE150525HA6 SYS PROYECTOS EMPRESARIALES, S.A. DE C.V. 500-05-2019-27927 dated September 25, 2019 25 October 2019

19 VPR140529V65 VINTAGE PROMOTIONS, S.A. DE C.V. 500-05-2020-13709 dated June 25, 2020 08 July 2020

20 ZAVJ780709F9A ZAMAGO VARGAS JUAN CARLOS 500-05-2019-27836 dated September 17, 2019 08 October 2019

Disagreeing with the individual presumption office or final resolution office, they filed means of defense from which the following resolution or sentence was concluded:

R.F.C. Name, denomination or corporate name of the Taxpayer Means of defense Date of the final Resolution or sentence Authority that resolved Sense and/or effect of the final resolution or sentence

1 ASE1501279F0 AGATA SERVICIO, S.A. DE C.V. Nullity Trial 6744/20-07-02-3 05 July 2023 Second Regional Chamber of the West, of the Federal Tribunal of Administrative Justice The nullity of the challenged resolution is declared, consisting of office number 600-51-2020- 02835 dated August 27, 2020, issued by the Concentrated Legal Administration of Sinaloa "1", through which the Revocation Appeal RRL2020004739 was dismissed, and the originally appealed resolution is left without effect, consisting of office 500-51-00-05- 02-2019-044451 dated November 26, 2019, issued by the Concentrated Administration of Fiscal Audit of Sinaloa "1".

2 ASE150130QK3 ASEPROVI, S.P.R. DE R.L. Nullity Trial 21/559-24-01-02-08-OL 06 July 2022 Specialized Chamber in Online Trials, of the Federal Tribunal of Administrative Justice The plain and simple nullity of the challenged resolution is declared, consisting of office number 500- 70-00-04-01-2019-01718 dated February 15, 2019, issued by the Concentrated Administration of Fiscal Audit of Zacatecas "1".

3 CEP1105261S7 CIRCON ENERGIA PROFESIONAL, S.A. DE C.V. Nullity Trial 6174/20-07-01-7 02 March 2022 First Regional Chamber of the West, of the Federal Tribunal of Administrative Justice The plain and simple nullity of the challenged resolution is declared, consisting of office number 600- 54-00-01-2020-1836 dated August 21, 2020, issued by the Concentrated Legal Administration of Sonora " 1 ", through which the Revocation Appeal RRL2020004081 was resolved, as well as of the originally appealed contained in office number 500-54-00-02-01-2020-0557 dated March 30, 2020, issued by the Concentrated Administration of Fiscal Audit of Sonora " 1 ".

4 CSG1201059UA COMERCIAL Y SERVICIOS GLOBALINC, S.A. DE C.V. Nullity Trial 4394/22-07-03-9-OT 28 February 2023 Third Regional Chamber of the West, of the Federal Tribunal of Administrative Justice The plain and simple nullity of the challenged resolution is declared, consisting of office number 500- 10-00-05-01-2020-42464 dated November 06, 2020, issued by the Concentrated Administration of Fiscal Audit of Baja California "2".

5 EEX060619ARA ESPINOZA EXPRESS, S.A. DE C.V. Nullity Trial 4810/19-03-02-12 14 February 2022 Second Regional Chamber of the Northwest III, of the Federal Tribunal of Administrative Justice The plain nullity of the challenged resolution is declared, consisting of office number 600- 10-00-00-00-2019-09986 dated August 21, 2019, issued by the Concentrated Legal Administration of Baja California Sur " 2 ", through which the Revocation Appeal RRL2019003822 was resolved, as well as of the originally appealed contained in office number 500-10-00-05-00-2019-14147 dated March 19, 2019, issued by the Concentrated Administration of Fiscal Audit of Baja California Sur " 2 ".

6 HENS9203206M3 HERNANDEZ NICASIO SINDY Nullity Trial 573/22-14-01-5 16 November 2022 Regional Chamber of the Pacific and Auxiliary, of the Federal Tribunal of Administrative Justice The plain and simple nullity of the challenged resolution is declared, consisting of office 500-27-00- 08-02-2021-02827 dated March 30, 2021, issued by the Concentrated Administration of Fiscal Audit of Guerrero "1".

7 HIM121126SA5 HUMAN IMPROVING COMPANY, S.C. Nullity Trial 1657/20-12-02-1 and its accumulated 1658/20-12-01-3 17 November 2021 Second Regional Chamber of the East, of the Federal Tribunal of Administrative Justice The plain and simple nullity of the challenged resolution is declared, consisting of office number 600- 71-00-01-00-2020-1990 dated March 18, 2020, issued by the Concentrated Legal Administration of the Federal District " 1 ", through which the Revocation Appeal RRL2019003697 was resolved, as well as of the originally appealed contained in office number 500-05-2019-7316 dated March 11, 2019, issued by the Central Administration of Strategic Taxation and by the attracted trial, the one consisting of office 500-05-2020-13771 dated July 17, 2020, issued by the Central Administration of Strategic Taxation, in compliance with what was resolved in the revocation appeal RRL2019003697,

by

the

Decentralized

Legal

Administration

of

the

Federal

District

"1".

8

LRU121205D33

LION

RISORSE

UMANE,

S.

DE

R.L.

DE

C.V.

Nullity Suit

20/282-

24-01-03-09-OL

05

of

July

of

2021

Specialized

Chamber

for

Online

Trials,

of

the

Federal

Tribunal

of

Administrative

Justice

The

nullity

of

the

challenged

resolution

is

declared

in

full,

consisting

of

office

number

600-

25-00-02-00-2019-1418

of

date

29

of

November

of

2019,

issued

by

the

Decentralized

Legal

Administration

of

Guanajuato

"2",

through

which

the

Revocation

Appeal

RRL2019007471

and

accumulated

RRL2019008190

were

resolved,

as

well

as

the

originally

appealed

one

contained

in

office

number

500-25-

00-05-02-2019-8995

of

date

28

of

June

of

2019,

issued

by

the

Decentralized

Administration

of

Fiscal

Audit

of

Guanajuato

"2".

9

MGS140520TH3

MAR

DEL

GOLFO

SUPPLY

OF

CONSTRUCTION,

S.A.

DE

C.V.

Nullity Suit

21/849-

24-01-03-06-OL

31

of

May

of

2022

Specialized

Chamber

for

Online

Trials,

of

the

Federal

Tribunal

of

Administrative

Justice

The

nullity

of

the

challenged

resolution

is

declared

in

full,

consisting

of

office

number

600-

19-00-00-00-2021-1120

of

date

23

of

April

of

2021,

issued

by

the

Decentralized

Legal

Administration

of

Chiapas

"1",

through

which

the

Revocation

Appeal

RRL2021001735

was

resolved,

which

confirms

the

originally

appealed

one

contained

in

office

number

500-19-00-05-01-2020-13306

of

date

10

of

December

of

2020,

issued

by

the

Decentralized

Administration

of

Fiscal

Audit

of

Chiapas

"1".

10

NCA9804022P8

NYSSEN

CONSULTANTS

ASSOCIATED,

S.C.

Nullity Suit

40/20-24-

01-6

Ac.

63

03

of

May

of

2022

Regional

Chamber

of

Morelos,

of

the

Federal

Tribunal

of

Administrative

Justice

The

nullity

of

the

challenged

resolution

is

declared,

consisting

of

office

number

600-

39-00-02-00-2019-4883

of

date

11

of

November

of

2019,

issued

by

the

Decentralized

Legal

Administration

of

Morelos

"1",

through

which

the

Revocation

Appeal

RRL2019009914

was

resolved,

as

well

as

the

originally

appealed

one

contained

in

office

number

500-39-00-06-02-2019-5492

of

date

23

of

May

of

2019,

issued

by

the

Decentralized

Administration

of

Fiscal

Audit

of

Morelos

"1".

11

OBA1701182Q7

OBANUAR,

S.A.

DE

C.V.

Nullity Suit

1743/22-

06-03-3

06

of

March

of

2023

Third

Regional

Chamber

of

the

Northeast,

of

the

Federal

Tribunal

of

Administrative

Justice

The

nullity

of

the

challenged

resolution

is

declared

in

full,

consisting

of

office

number

600-

42-2022-1-9-576

of

date

01

of

February

of

2022,

issued

by

the

Decentralized

Legal

Administration

of

Nuevo

León

"2",

through

which

the

Revocation

Appeal

RRL2021011060

was

resolved,

as

well

as

the

originally

appealed

one

contained

in

office

number

500-42-

00-08-03-2021-02855

of

date

15

of

July

of

2021,

issued

by

the

Decentralized

Administration

of

Fiscal

Audit

of

Nuevo

León

"2".

12

PSM1407309KA

SERVICE

PROVIDER

MURATA,

S.A.

DE

C.V.

Nullity Suit

28865/21-

17-05-9

07

of

December

of

2022

Fifth

Regional

Metropolitan

Chamber,

of

the

Federal

Tribunal

of

Administrative

Justice

The

nullity

of

the

confirmatory

resolution

implied

from

the

revocation

appeal

RRL2021001681,

attributed

to

the

Decentralized

Legal

Administration

of

the

Federal

District

"4",

is

declared,

as

well

as

the

originally

appealed

one

contained

in

office

number

500-74-

06-03-01-2020-5671

of

date

10

of

December

of

2020,

issued

by

the

Decentralized

Administration

of

Fiscal

Audit

of

the

Federal

District

"4".

13

PCR171223S34

PROJECTS

AND

CONSTRUCTIONS

ROXI,

S.A.

DE

C.V.

Nullity Suit

1040/20-

15-01-7

14

of

March

of

2022

Regional

Chamber

of

the

Southeast,

of

the

Federal

Tribunal

of

Administrative

Justice

The

nullity

of

the

challenged

resolution

is

declared

in

full,

consisting

of

office

number

500-

44-00-00-00-2020-04101

of

date

29

of

June

of

2020,

issued

by

the

Decentralized

Administration

of

Fiscal

Audit

of

Oaxaca

"1".

14

RSI1602151T1

RH

INTELLIGENT

SERVICES,

S.

DE

R.L.

DE

C.V.

Nullity Suit

4194/22-

17-08-2

18

of

April

of

2023

Eighth

Regional

Metropolitan

Chamber

The

nullity

of

the

challenged

resolution

is

declared,

consisting

of

office

number

600-

74-00-02-00-2021-17955

of

date

15

of

December

of

2021,

issued

by

the

Decentralized

Legal

Administration

of

the

Federal

District

"4",

through

which

the

Online

Revocation

Appeal

RRL2021000423

was

resolved,

as

well

as

the

originally

appealed

one

contained

in

office

number

500-05-2020-28635

of

date

13

of

November

of

2020,

issued

by

the

Central

Administration

of

Strategic

Taxation,

in

compliance

with

the

resolution

to

the

Online

Revocation

Appeal

RRL2019004658

contained

in

office

600-74-00-02-00-2019-13465

of

date

18

of

December

of

15

SCI150216KB7

SCISPRO,

S.A.

DE

C.V.

Nullity Suit

3786/21-

07-02-1

23

of

August

of

2022

Second

Regional

Chamber

of

the

West,

of

the

Federal

Tribunal

of

Administrative

Justice

The

nullity

of

the

challenged

resolution

is

declared,

consisting

of

office

600-32-2021-

01664

of

date

18

of

March

of

2021,

issued

by

the

Decentralized

Administration

of

Jalisco

"3",

through

which

it

dismissed

the

revocation

appeal

RRL2020006744,

as

well

as

the

originally

appealed

resolution,

consisting

of

the

one

contained

in

office

500-32-00-05-06-2020-

3134

of

24

of

June

of

2020,

issued

by

the

Decentralized

Administration

of

Fiscal

Audit

of

Jalisco

"3".

16

SSE1603045L5

SENESTE

SERVICES,

S.A.

DE

C.V.

Nullity Suit

5347/20-

07-02-4

07

of

December

of

2022

Second

Regional

Chamber

of

the

West,

of

the

Federal

Tribunal

of

Administrative

Justice

The

nullity

of

the

challenged

resolution

is

declared

in

full,

consisting

of

office

number

600-

69-2020-01597

of

date

27

of

April

of

2020,

issued

by

the

Decentralized

Legal

Administration

of

Yucatán

"1",

through

which

the

Revocation

Appeal

RRL2018009155

was

resolved,

as

well

as

the

originally

appealed

one

contained

in

office

number

500-69-

00-06-02-2020-882

of

date

20

of

January

of

2020,

issued

by

the

Decentralized

Administration

of

Fiscal

Audit

of

Yucatán

"1".

17

SCO150420DH8

STP

CONSTRUCTIONS,

S.A.

DE

C.V.

Nullity Suit

841/21-

30-01-3-OT

04

of

April

of

2023

Regional

Chamber

of

the

Center

IV

and

Auxiliary,

of

the

Federal

Tribunal

of

Administrative

Justice

The

nullity

of

the

challenged

resolution

is

declared,

consisting

of

office

number

600-

25-00-02-00-2021-066

of

date

08

of

February

of

2021,

issued

by

the

Decentralized

Legal

Administration

of

Guanajuato

"2",

through

which

the

Revocation

Appeal

RRL2020009486

was

resolved,

as

well

as

the

originally

appealed

one

contained

in

office

number

500-25-00-06-01-2020-14430

of

date

15

of

September

of

2020,

issued

by

the

Decentralized

Administration

of

Fiscal

Audit

of

Guanajuato

"2".

18

SPE150525HA6

SYS

BUSINESS

PROJECTS,

S.A.

DE

C.V.

Nullity Suit

8803/20-

17-14-4

09

of

February

of

2022

Fourteenth

Regional

Metropolitan

Chamber,

of

the

Federal

Tribunal

of

Administrative

Justice

The

nullity

of

the

challenged

resolution

is

declared,

consisting

of

office

number

600-

74-00-02-00-2020-1024

of

date

30

of

January

of

2020,

issued

by

the

Decentralized

Legal

Administration

of

the

Federal

District

"4",

through

which

the

Revocation

Appeal

RRL2019007140

was

resolved,

as

well

as

the

originally

appealed

one

contained

in

office

number

500-74-05-03-01-2019-7721

of

date

26

of

June

of

2019,

issued

by

the

Decentralized

Administration

of

Fiscal

Audit

of

the

Federal

District

"4",

for

the

effect

that

the

defendant

reinstates

the

presumption

procedure

of

non-existence

of

operations

initiated

against

the

plaintiff,

and

in

terms

of

the

fourth

paragraph,

of

article

69-

B

of

the

Federal

Tax

Code,

carry

out

the

request

for

the

corresponding

documentation.

19

VPR140529V65

VINTAGE

PROMOTIONS,

S.A.

DE

C.V.

17873/20-17-13-5/02-03-6

30

of

September

of

2022

Second

Regional

Metropolitan

Chamber

of

the

Federal

Tribunal

of

Administrative

Justice

The

nullity

of

the

challenged

resolution

is

declared,

consisting

of

office

number

600-

71-00-02-00-2020-4002

of

date

24

of

August

of

2020,

issued

by

the

Decentralized

Legal

Administration

of

Guerrero

"1",

through

which

the

Revocation

Appeal

RRL2020003917

was

resolved,

as

well

as

the

originally

appealed

one

contained

in

office

number

500-27-00-08-02-2020-03510

of

date

20

of

March

of

2020,

issued

by

the

Decentralized

Administration

of

Fiscal

Audit

of

Guerrero

"1".

20

ZAVJ780709F9A

ZAMAGO

VARGAS

JUAN

CARLOS

Nullity Suit

1397/22-

05-02-2

17

of

January

of

2023

Second

Regional

Chamber

of

the

North

Center

II,

of

the

Federal

Tribunal

of

Administrative

Justice

The

nullity

of

the

challenged

resolution

is

declared

in

full,

consisting

of

office

500-05-2019-

27836,

issued

by

the

Central

Administration

of

Strategic

Taxation,

corresponding

to

taxpayers

who,

DID

not

provide

arguments

and/or

evidence,

to

disprove

the

reason

for

which

they

were

notified

of

the

presumption

office,

reason

for

which

the

situation

referenced

in

the

first

paragraph

of

article

69-

B

of

the

Federal

Tax

Code

was

DEFINITIVELY

actualized,

in

particular

to

the

individual

office

number

500-16-00-

00-00-2019-5540

of

date

09

of

April

of

2019,

issued

by

the

Decentralized

Administration

of

Fiscal

Audit

of

Coahuila

of

Zaragoza

"2".

In

virtue

of

the

above,

it

is

informed

that,

as

a

consequence

of

the

legal

defenses

indicated

in

the

preceding

paragraph,

the

procedure

of

article

69-B

of

the

Federal

Tax

Code,

followed

against

those

taxpayers

also,

has

become

void.

Finally,

it

is

informed

that

the

fact

that

the

aforementioned

taxpayers

have

obtained

a

favorable

resolution

against

the

presumption

offices

and/or

definitive

resolutions,

does

not

exempt

them

from

the

responsibility

they

may

have

regarding

other

tax

vouchers

they

have

issued

without

having

the

assets,

personnel,

infrastructure

or

material

capacity,

directly

or

indirectly,

to

provide

the

services

or

produce,

commercialize

or

deliver

the

goods

that

such

vouchers

covered,

for

which

the

powers

of

the

tax

authority

are

reserved.

Respectfully.

Mexico

City,

on

08

of

November

of

  • In

substitution

for

absence

of

the

Central

Administrator

of

Strategic

Taxation,

of

the

Coordinator

of

Strategic

Taxation,

of

the

Administrator

of

Strategic

Taxation

"1",

"2",

"3",

"4",

"5"

and

"6",

based

on

articles

4,

fourth

paragraph,

and

22,

last

paragraph,

numeral

5

inciso

h),

of

the

Internal

Regulations

of

the

Tax

Administration

Service

in

force,

signs:

Administrator

of

Strategic

Taxation

"7",

L.C.

Susana

Herrera

Maldonado

.-

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