» Resolution of the Supreme Court of Ukraine as of February 23, 2023, in case No. 640/17091/21 that the taxpayer’s appeal of the order to conduct a tax audit is not a dispute about the right within the meaning of Clause 2, Part 4 of Article 283 of the Code of Administrative Procedure of Ukraine and does not prevent the consideration of an application for confirmation the validity of the administrative seizure of the taxpayer’s property