ABSTRACT

Nantong Development Zone Fuda Special Chemical Limited Company (hereinafter FD) claimed that, from 1997 to 1998, the relevant “concrete administrative acts” (acts) of the Nantong Office of the State Administration of Taxation (hereinafter NSAT) were illegal and infringed upon its legal rights and interests. Although it had filed administrative lawsuits against the NSAT with the relevant courts at Nantong City at various times, the courts either dismissed the lawsuits or affirmed the acts. On 30 December 1999, FD submitted three applications for administrative reconsideration to the Jiangsu Office of the State Administration of Taxation (hereinafter JSAT), alleging that the NSAT had infringed upon its legal rights.