In his concurrent opinion the Judge pointed out that the evaluative methods in question are relative and conventional, and the substitution of one conventional evaluation with another one, presumptively more precise, does not necessarily mean that the former (the State cadastre assessment), is  wrong, unjust (is set too high or too low) and thus entails an unlawful determination of tax  base with ungrounded increase of tax obligations. Besides, the case law of the Supreme Commercial Court permits calculating land tax in accordance with a newly determined cadastre value from the very moment of a change in the form of permissible use of land plot, not awaiting the following tax period. The applicant is not deprived of the right to correct or review the cadastre value of the land plot as of the date when it has been determined in the way that violated his rights, but uncertainties as to the circumstances of the applicant’s court cases do not allow to  be sure that the application of the contested provisions has indeed entailed the violation of his rights in the sense he  put it in the application.