PROCEDURES FOR CONSIDERING TAX DISPUTES IN ADMINISTRATIVE COURTS AND THE PARTICIPANTS IN THE PROCESS: LEGAL ANALYSIS IN THE CONTEXT OF UZBEKISTAN'S ADMINISTRATIVE JUSTICE SYSTEM

Abstract

This article examines the procedural framework and participants in the consideration of tax disputes in administrative courts in the Republic of Uzbekistan. The study begins with a doctrinal clarification of the foundational concepts of administrative procedure, administrative process, and administrative proceedings -- concepts whose precise delimitation is indispensable for the correct understanding of the procedural rules applicable to tax disputes. Drawing on the scholarship of Igor Tsai and Erkin Khodzhiev, as well as on the constitutional foundations of administrative procedure in the United States, the article situates Uzbekistan's procedural framework within a broader comparative and theoretical context. The article then examines the tripartite distribution of jurisdiction over tax disputes among economic courts, civil courts, and administrative courts, analyzing the distinct procedural rules applicable in each forum. Special attention is devoted to the procedural architecture of administrative court proceedings in tax cases -- including requirements relating to applications, time limits, restoration of missed deadlines, the appointment and assessment of expert evidence, and the obligations of courts when reviewing tax audit decisions. The article addresses the powers of administrative courts upon finding that a tax authority decision is invalid or that official action is unlawful, including the obligation to impose corrective duties on the relevant authority. The article concludes that the development of specialized administrative courts in Uzbekistan marks a decisive transition from a general judicial form of administrative justice to a specialized judicial form, with significant implications for the quality and consistency of tax dispute adjudication.