The Supreme Court revokes Piña’s protection in favor of Minera d

Minister Lenia Batres explained that the mining company sent promotions to the SCJN to try to postpone the resolution of this appeal.

Mexico City, October 31 (However).- The Supreme Court of Justice of the Nation (SCJN) approved yesterday unanimity and project to revoke a agreementpresented by the former president of the Court Norma Lucía Piña Hernándezso that First Mining Company, SA de CV defer payment of a debt of the one thousand 868 million 853 thousand 516 pesos for the concept of Income Tax (ISR).

“With this, the decision of the Second Collegiate Court on Administrative Matters of the First Circuit, of January 25, 2025, which denied protection to the complaining mining company against the payment of two thousand 868 million 853 thousand 516 pesos, for income and business taxes at a single rate, plus updates, surcharges and fines, corresponding to the fiscal year of 2012, is final,” explained Minister Lenia Batres in a statement.

The above, because the SCJN determined that the matter does not have the characteristics of exceptionality in constitutional or human rights matters, such as to be reviewed by said Court.

Announcement 22/2025

The #NewSCJN unanimously resolved to revoke the agreement by which the then president of the Court admitted an appeal for review in amparo filed by a mining company.

What did the Court decide?
The agreement that admitted the appeal of… is revoked pic.twitter.com/sSsgjLEug2

— Lenia Batres (@LeniaBatres) October 31, 2025

Lenia Batres also maintained that the Second Chamber of the highest court has already repeatedly addressed the issue of the constitutionality of Article 46, section Ill, of the Federal Law of Contentious Administrative Procedure, challenged by the mining company in this amparo.

Questions regarding articles 34-A and 42 of the Federal Tax Code are also inadmissible, since the collegiate court already indicated that the premises referred to by the complaining party were based on facts that did not occur in the specific case; Therefore, there is no exceptionality on this topic either, in addition to the fact that there are several theses on the powers of tax verification.

“Finally, I explained that, although the mining company sent promotions to the SCJN to try to postpone the resolution of this appeal, arguing that it was already in talks with the federal government to resolve this debt, there is no type of alternative solution mechanism, so it is not appropriate to continue delaying a solution,” commented Batres Guadarrama.

In this same session, the Minister expressed that she voted with the majority in favor of granting protection to several companies dedicated to tourism in protected natural areas, national parks and biosphere reserves, who were fighting the collection of fees to carry out their activities in these areas.