Overview
- SAT must pay Grupo Televisa 103,073,347 pesos with inflation updates, and the refund cannot be blocked.
- The 6–3 decision came in amparo en revisión 2473/2025, adopting Minister Irving Espinosa Betanzo’s project to dismiss the Treasury’s appeal.
- The new payment is additional to 288,671,887 pesos previously returned and stems from improper taxes tied to fiscal years 1998, 1999, 2003 and 2004.
- In a separate ruling resolving contradiction 158/2018, the Court set a binding precedent that interest is not automatic when a fiscal credit is annulled and applies only if a judgment expressly orders a refund.
- Ministers Lenia Batres Guadarrama and María Estela Ríos González dissented on standing and fiscal impact, with Arístides Rodrigo Guerrero García also voting against.