Hence the very important assessment that self-binding

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Precisely as a result of the circumstance that legal formulas are insufficient to resolve all conflicts arising in society . In other words, the prohibition of contradictory behavior serves as an instrument of material justice in cases of violation of the legitimate trust of those administered that are not resolved by any rule of positive law.  of contradictory behavior, one could raise the idea of ​​the need for subjective identity, which would require that the understandings that generate legitimate trust and damage must emanate from the same legal entity, that is, from the same administrative body.

As in the situation under analysis we have different bodies (Federal Revenue and Carf), it would not be possible to apply the principle. However, according to the most current doctrine of administrative law, this is not the understanding that aligns with the affirmation of the principle of legal certainty as the basis for the constitutional duty EX Mobile Phone Numbers of administrative coherence. Given the complexity of the social fabric to be achieved by the different arms of public power, it is essential that there be decentralizations to improve the performance of administrative functions, preserving the unity of the public law legal entity of which they form part.



This however, does not eliminate, but rather attracts, the need for a congruent, harmonious performance of the entities and bodies that make up this administrative network [5] . Therefore, even if contradictory acts emanate from bodies with different competences, "the criterion for assessing the occurrence of the subjective identity requirement will continue to be that of the same Public Administration, whose unity does not cease to exist due to its internal organizational division.