The revision of the cadastral class It is a delicate theme that directly touches thousands of real estate owners. The Revenue Agency, in certain cases, can change the class of a property, consequently increasing its cadastral pension And, therefore, the taxes for the owner.

But how far this revision is legitimate?

A recent sentence of the Court of Cassation has established an important principle: the agency must provide clear motivation and detailed to justify the increase in cadastral income. Otherwise, the taxpayer has the right to challenge the provision and obtain its cancellation.

What does this decision mean for property owners? What tools do they have available to defend themselves from unjustified cadastral increases?

Let’s find out in detail.

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Reclassification cAtastal and the appeal of the taxpayer

The case in question concerns a property located in Rome, whose owner has been seen Increase the cadastral income following a revision of the classification made by the Revenue Agency. In particular, the property, originally classified in the category A/10 Class 4was reclassified in A/10 class 7with an increase in the annuity from 4,325.33 euros to 6,817.23 euros.

The reason behind the review was the increase in the average value of the properties in the reference microzone, which, according to the Revenue Agency, would have exceeded the city average by 35%. This revaluation, according to the territory office, justified the recalculation of the cadastral income, involving a consequent increase in the taxes due by the owner.

The taxpayer, considering this variation unjustified, challenged the assessment notice by appealing to the Provincial Tax Commission (CTP) of Rome. However, his appeal was rejected.

Subsequently, he appealed to the Regional Tax Commission (CTR) of Lazio, but this also confirmed the legitimacy of the agency’s work.

At this point, the taxpayer decided to bring the question before the Court of Cassationclaiming that the agency’s measure was spoiled by lack of motivation and that the calculation criteria adopted for reclassification had not been clearly indicated.

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The reasons for the decision of the Cassation

The Court of Cassation, with sentence no. 4684/2025, accepted the taxpayer’s appeal, believing that the provision of the Revenue Agency was lacking in motivation. According to the Supreme Court, a cadastral assessment notice must contain a clear and detailed explanation of the reasons that justify the revision of the class. In the specific case, the agency had limited itself to reporting that the microzone market value It had increased over 35% compared to the average city, but without specifying how the calculation had been carried out or what the sources used were to determine the new value.

Another aspect highlighted by the Cassation concerns administrative transparency. The cadastral review, in fact, cannot be based on generic statements relating to the increase in the real estate value of an area, but must precisely indicate the criteria adopted to evaluate this increase and demonstrate how this impacts on the individual real estate unit.

In the absence of these elements, the taxpayer does not have the tools to verify the correctness of the decision and, if necessary, to contest it.

The sentence also underlined an incorrect application of the microzone legislation. The law provides that a cadastral review is justified only in the so -called “anomalous microzone”, that is, those in which the relationship between the average market value and the average cadastral value differs significantly from the municipal average. However, the Cassation clarified that a generic deviation is not enough to justify an increase in cadastral income.

The agency should have demonstrated concretely that this variation had a specific impact on the classification of the taxpayer’s property.

In pronouncing on the case, the Cassation has recalled previous jurisprudentials that confirm the obligation of a rigorous motivation in the cadastral reviews, including the Cass judgments. 9035/2024, 30448/2024 and 31096/2023. Following this orientation, the Court considered the cadastral assessment illegitimate and canceled the increase in the annuity.

Furthermore, he decided to compensate the legal expenses between the parties, considering that the legal question in question has been the subject of a jurisprudential consolidation only in recent years.