Answer: No, it cannot.
According to Clause 2 of Article 151 of Federal Decree-Law No. 42 of 2022 Promulgating the Civil Procedure Code, an appellant may not be put in a worse position due to their own appeal if no other party has filed an appeal.
If only one party files an appeal (e.g., the taxpayer), the court cannot issue a judgment that worsens their position, such as increasing the amount to be repaid or ordering more than was previously ruled.
Relevant case law:
Case No. 299 of 2025 / Federal Supreme Court / Administrative