Tax assesment Committee (MPP) doesn't meet requirement for an administrative appelate committee. Administrative appelate committee must be a government agency but in fact, it is an independent not a government committee. regarding the judical review of a court justice and administrative appelate committee in article 48 of the law No. 5 of 1986, tax assesment committee should review efficiency (doelmatig-heidstoetsing) other than legality ( rechtmatigheid- stoetsing)