Notice 500-05-2025-39145 Communicating List of Taxpayers Who Challenged Presumption Notices Under Article 69-B of the Federal Tax Code and Obtained Favorable Rulings

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DOF: 06/03/2026

OFFICE 500-05-2025-39145 through which a list of taxpayers who promoted some means of defense against the presumption notice referred to in the first paragraph of Article 69-B of the Federal Tax Code, valid until July 24, 2018, or against the resolution referred to in the third paragraph of the aforementioned article, and once resolved, the jurisdictional or administrative body left the referred act unsubstantiated.

At the margin, a seal with the National Coat of Arms, which says: United Mexican States.- Treasury.- Ministry of Finance and Public Credit.- Tax Administration Service.- General Administration of Federal Fiscal Audit.- Central Administration of Strategic Audit.

OFFICE: 500-05-2025-39145

Subject:

A list of taxpayers who promoted some means of defense against the presumption notice referred to in the first paragraph of Article 69-B of the Federal Tax Code (CFF), valid until July 24, 2018, or against the resolution referred to in the third paragraph of the aforementioned article, and once resolved, the jurisdictional or administrative body left the referred act unsubstantiated.

This Central Administration of Strategic Audit, attached to the General Administration of Federal Fiscal Audit, of the Tax Administration Service, based on what is established by 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, effective from November 22, 2015, in accordance with what is established 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 Finance 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 Agency of Customs of Mexico are issued, published in the same official organ on December 21, 2021, effective from January 1, 2022, in accordance with what is established 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, effective from July 23, 2016, in accordance with what is established in the First Transitory Article of said Agreement; in Articles 33, last paragraph, 63 and 69-B, first and second paragraphs of the Federal Tax Code valid until July 24, 2018, in relation to the Second Transitory Article of the "DECREE by which Article 69-B of the Federal Tax Code is reformed", published in the Official Gazette of the Federation on June 25, 2018 and Eighth Transitory Article, fraction IV, of the Fiscal Miscellany Resolution for 2025, published in the Official Gazette of the Federation on December 30, 2024, communicates the following to you:

That to the taxpayers listed below, a Presumption Notice of non-existence of operations backed by certain fiscal receipts they issued was notified at the time, in accordance with the first and second paragraphs of Article 69-B of the Federal Tax Code, valid until July 24, 2018, in relation to Article 69 of its Regulations.

Following the procedure provided for in the aforementioned Article 69-B of the Federal Tax Code, valid until July 24, 2018, and in terms of the third paragraph of the mentioned article, the taxpayers in reference were notified of the definitive resolution as indicated below:

Notification to taxpayers of the OFFICE OF THE DEFINITIVE RESOLUTION.

No.

R.F.C.

Name, denomination or corporate name of the Taxpayer

Number and date of definitive resolution office

Means of notification to the taxpayer

Authority's public notice board

Personal Notification

Tax Box

Date of posting on the Fiscal Authority's public notice board

Date on which the notification took effect

Date of notification

Date on which the notification took effect

Date of notification

Date on which the notification took effect

01

ADE121001K34

ADETSA, S.A. DE C.V.

500-42-00-08-03-2019- 3789 of July 1, 2019

August 1, 2019

August 26, 2019

02

CMO0706268S6

CYS MOVILES, S.A. DE C.V.

500-42-00-04-03-2018- 02155 of March 2, 2018

March 8, 2018

March 9, 2018

03

GAGA860718GI4

GARDUZA GARCIA ARMANDO

500-57-00-05-01-2017- 006310 of September 1, 2017

September 5, 2017

September 28, 2017

04

ISU130521FH3

INGREDIENTES DEL SUR, S.A. DE C.V.

500-20-00-04-00-2017- 1307 of February 24, 2017

March 2, 2017

March 3, 2017

05

NCO120713IN8

NNH EMPRESARIAL, S.A. DE C.V.

500-04-00-00-00-2016- 13526 of April 20, 2016

May 3, 2016

May 4, 2016

Additional data of the taxpayers.

No.

R.F.C.

Name, denomination or corporate name of the Taxpayer

Fiscal Address

Preponderant Activity

Reason for the Procedure

01

ADE121001K34

ADETSA, S.A. DE C.V.

Guadalupe, Nuevo León

Business administration services

No material capacity

02

CMO0706268S6

CYS MOVILES, S.A. DE C.V.

Matamoros, Tamaulipas

Rental of equipment for commerce and services

Absence of Assets

Absence of Personnel

Lack of infrastructure

No material capacity

03

GAGA860718GI4

GARDUZA GARCIA ARMANDO

Villahermosa, Tabasco

Construction of commercial, institutional and service buildings

Absence of Assets

Absence of Personnel

04

ISU130521FH3

INGREDIENTES DEL SUR, S.A. DE C.V.

Tapachula, Chiapas

Elaboration of other foods

Absence of Assets

Absence of Personnel

05

NCO120713IN8

NNH EMPRESARIAL, S.A. DE C.V.

Monterrey, Nuevo León

Other services related to real estate services

Absence of Assets

Absence of Personnel

Lack of infrastructure

No material capacity

For the above, the name or corporate name of the taxpayers to whom the aforementioned resolutions were notified, were added to the list referred to in the third paragraph of Article 69-B of the Federal Tax Code, valid until July 24, 2018, which was published in the Official Gazette of the Federation, as indicated below:

No.

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

01

ADE121001K34

ADETSA, S.A. DE C.V.

500-05-2021-26013 dated September 15, 2021

October 11, 2021

02

CMO0706268S6

CYS MOVILES, S.A. DE C.V.

500-05-2018-14172 dated May 25, 2018

June 28, 2018

03

GAGA860718GI4

GARDUZA GARCIA ARMANDO

500-05-2018-572 dated January 26, 2018

February 26, 2018

04

ISU130521FH3

INGREDIENTES DEL SUR, S.A. DE C.V.

500-05-2017-16088 dated May 16, 2017

May 29, 2017

05

NCO120713IN8

NNH EMPRESARIAL, S.A. DE C.V.

500-05-2016-27032 dated July 14, 2016

July 26, 2016

Disagreeing with the individual presumption office or definitive resolution office, they filed means of defense, which were concluded with the following resolution or sentence:

No.

R.F.C.

Name, corporate name of the Taxpayer

Means of defense

Date of the Resolution or firm sentence

Authority that resolved

Sense and/or effect of the resolution or firm sentence

01

ADE121001K34

ADETSA, S.A. DE C.V.

Nullity Trial 22093/22- 17-02-4

May 15, 2024

Second Metropolitan Regional Chamber of the Federal Court of Administrative Justice

The nullity of the challenged resolution 600- 42-2022-04-5041 of August 9, 2022, issued by the Decentralized Legal Administration of Nuevo León "3", through which, the taxpayer was informed that: "the correct way to file the Revocation Appeal, is through the Tax Box on the SAT Portal, and that this authority deemed the promotion presented by the legal representative of that legal entity, promoted against the various 500-42-00- 06-01-2018-04508 of July 10, 2018 and 500-42-00- 08-03-2019-3789 of July 1, 2019, both issued by the Decentralized Administration of Fiscal Audit of Nuevo León "2", to be admissible.

02

CMO0706268S6

CYS MOVILES, S.A. DE C.V.

Nullity Trial 978/21- EC2-01-04-OT

October 11, 2023

Second Specialized Chamber in Foreign Trade and Auxiliary Chamber of the Federal Court of Administrative Justice

The nullity of the challenged resolution 500-42-00-04-03-2018-02155 of March 2, 2018, issued by the Decentralized Administration of Fiscal Audit of Nuevo León "2", is declared outright.

03

GAGA860718GI4

GARDUZA GARCIA ARMANDO

Nullity Trial 673/22-26- 01-1

June 1, 2023

Regional Chamber of Tabasco and Auxiliary of the Federal Court of Administrative Justice

The nullity of the challenged resolution 500-57-00-05-01-2017-006310 of September 1, 2017, issued by the Decentralized Administration of Fiscal Audit of Tabasco "1", is declared outright.

04

ISU130521FH3

INGREDIENTES DEL SUR, S.A. DE C.V.

Nullity Trial 4420/17- 10-01-3-OT

May 10, 2019

Regional Chamber of the Center III of the Federal Court of Administrative Justice

The nullity of the challenged resolution 600- 26-00-00-00-2017-3811 of July 21, 2017, issued by the Decentralized Legal Administration of Guanajuato "3", which resolved the Online Administrative Revocation Appeal RRL2017003721, as well as, of the originally challenged 500-20-00-04-00-2017-1307 dated February 24, 2017, signed by the Decentralized Administration of Fiscal Audit of Chiapas "2", is declared.

05

NCO120713IN8

NNH EMPRESARIAL, S.A. DE C.V.

Nullity Trial 314/21- EC2-01-2

September 18, 2024

Fourth Regional Chamber of the Northeast of the Federal Court of Administrative Justice

The nullity of the challenged resolution 500-04-00-00-00-2016-13526 of April 20, 2016, issued by the Central Administration Verification and Evaluation of Federal Entities in Fiscal Coordination, is declared outright.

In view of the above, it is communicated that, as a consequence of the means of defense indicated in the preceding paragraph, the procedure of Article 69-B of the Federal Tax Code valid until July 24, 2018, followed against those taxpayers, has become without effect.

Finally, it is informed that the fact that the aforementioned taxpayers have obtained a favorable resolution against the presumption notice and/or definitive resolution, does not exempt them from the responsibility they may have regarding other fiscal receipts they may 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 backed such receipts, for which reason, the powers of the tax authority are reserved.

Respectfully.

Mexico City, November 25, 2025.- Central Administrator of Strategic Audit, L.C. Rubén Martín López Rodríguez .- Rubric.

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