As an extraordinary legal remedy, a review interferes with a final or finally settled administrative-law relationship in order to remedy procedural irregularities that occurred in the previous proceedings, which may have rendered the decision unlawful and prejudiced the legal position of a party, or of someone who was not a party but should have been, in a way that is not legally permissible. In doing so, it is necessary to ensure an appropriate balance between legality and legal certainty, ensuring the stability of concrete legal relationships.
This was also made clear in the legislature, which limited the allowability of the procedure through various conditions, which I present in more detail in the master's and the following section. I derive, in particular, from the observations of the case-law, which is why I analise some specific cases dealt with by the Administrative Court, as well as from the observations and opinions of the Supreme and Constitutional Courts. In the constitutionality assessment procedure, the latter has already dealt with the question of the possible shortcomings of Article 260 of the ZUP, as it contains only a few tax-determined restorative reasons, which severely limits cases where renewal is even permitted.
I also examine the title theme in the light of possible changes in administrative judicial practice. I present four segments in the case-law for which I explain trends in the future.
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