Overview

• Registered as Amparo Directo en Revisión 5145/2025, the case was assigned to Minister President Hugo Aguilar Ortiz, who will present the draft judgment to the full court.
• The Supreme Court accepted the case solely to assess the constitutionality of Article 31 of the Income Tax Law, leaving aside the underlying accounting and deduction disputes settled by lower courts.
• The challenged assessment traces to the 2012 fiscal year and is reported at roughly 1.6 billion pesos in ISR, updates, surcharges and fines.
• Under the reformed procedures, the Court must resolve admitted fiscal reviews within six months from admission or explain any delay to the judicial disciplinary authority.
• Grupo Elektra and Ricardo Salinas Pliego still face additional SAT claims totaling tens of billions of pesos, while separate U.S. proceedings with AT&T include a contempt finding and a reported $25 million bond payment.