Overview

• SCJN President Hugo Aguilar Ortiz admitted the review and took the case in his chamber, registered as Amparo Directo en Revisión 5145/2025, to draft a project for the full court.
• Under the 2024 reform, fiscal reviews must be resolved within six months, setting an outer limit that points to a decision by March 2026 unless the matter is dismissed sooner.
• The Court will only examine the constitutionality of Article 31 of the Income Tax Law, leaving intact lower-court findings on Elektra’s stock-loss deductions from the 2012 filing.
• The contested ISR credit totals 1,609 million pesos from 2012, previously affirmed by the Décimo Tribunal Colegiado, while authorities cite broader liabilities for Salinas Pliego’s group of about 74 billion pesos.
• Elektra still faces additional high-value disputes exceeding 33 billion pesos and has recently lost related amparos on 2010 and 2011 credits, with separate U.S. proceedings reported to include a $25 million bond tied to an AT&T case.