The Beersheba District Court has refused a wood import and marketing company's request for more time to appeal a VAT assessment of ₪380,148. The decision was reported on 20 October 2026. The company said it did not know its objection had been rejected until a lien arrived. The court held that the decision counts as delivered in November 2025, because it went by registered mail to the company's registered address.
Sixty days that started at the post office
The Ashdod VAT Manager assessed the company after finding that credit notes it issued to cancel earlier tax invoices broke the VAT Law and the bookkeeping regulations. The company filed an objection, which was heard in July 2025. In mid-November 2025 the Manager rejected it.
The decision was sent by registered mail on 17 November 2025. Under the presumption of delivery in section 141 of the VAT Law, it is treated as received on 24 November. The 60-day appeal period ran from that date and ended in late January 2026.
No appeal was filed. In February 2026 the Manager sent four payment demands, and in early May a lien was placed with a third party. The company says its accountant only learned of the decision after the lien, and the first copy it received came by email in June. It asked for an extension on 23 June 2026, about five months after the assessment became final.
Willful blindness, in the court's words
The company argued that the Manager acted "in a rush" although he had all its contact details, and that the clock should run from the email. The Manager replied that the company was represented, knew a decision was coming and did nothing to collect its mail. The judge agreed with him. She said the statutory presumption of delivery exists for exactly this argument, and that refusing to collect registered mail while waiting for a decision is willful blindness. A valid reason for an extension has to come from outside, not from the applicant's own failure.
The court noted that it has been stricter with these requests since the new civil procedure rules, and that requests have been refused over delays of two months. The reason is practical. An appeal postpones payment of the tax until a ruling, so the deadline protects equal treatment of taxpayers and the state's ability to collect.
The credit notes and the duty to check
The company said its chances on appeal were high, "even absolute". Its account was that it was new to the market, and a project manager acting for it stole the imported wood, told it to issue tax invoices to customers, and the sales never happened. So it cancelled the invoices with credit notes.
The Manager said the credit notes did not meet the conditions of Instruction 23 of the bookkeeping regulations, which ruled out the exception in section 49 of the VAT Law. The judge pointed out that the company never explained how it met the conditions for issuing a credit note, and that the minutes of the objection hearing, which it submitted itself, suggested the goods had been sold. Citing earlier rulings, she added that whoever lets invoices go out in their name carries a heavy burden to check who they are dealing with. No evidence of such checks was presented.
The Manager had also pointed the company to the 2012 bad debt procedure. The court found it did not meet that procedure's conditions and gave no explanation. The request was dismissed, and the company has to pay ₪5,000 in costs within 30 days.
For a business waiting on the Tax Authority
A registered letter from the Tax Authority starts the clock even if nobody picks it up. An owner who has filed an objection, or is waiting on any decision from the Authority, should check the mail at the business's registered address and make sure that address is current with the Authority. If an accountant or lawyer is handling the case, agree in advance who watches the mail and who tracks the deadlines. Once a deadline has passed, the only route left is an extension request, and the court grants one only when the delay came from something outside the business's control.
Credit notes have rules too. In this case the court found no explanation of how the company met the conditions for issuing them. The details are in our credit note guide.