41. With regard to the facts, the State provided a narrative of the amparo proceeding and of the enforcement of judgment proceeding similar to that described by the petitioners adding that the SUNAT objected to the expert report of April 7, 2003, because it considered that it was illegal and contrary to the jurisprudence of the Constitutional Court. The State pointed out that the argument was accepted by the corresponding judicial authority which, on May 5, 2005, rejected the “multimillion expert report” issued and made it absolutely clear that the pensions could not be adjusted based on the salary scale of SUNAT employees under the private labor system and ordering a new expert report. 42. The State pointed out that the association appealed the decision on May 23, 2005, and that on May 23, 2006, the appeal was resolved when the earlier decision was reaffirmed. 43. The State pointed out that the new expert report followed the same criteria that determined the rejection of the first expert report and that led to a resolution issued on March, 17, 2006, ordering SUNAT to adjust the pensions and pay the increases not received to 566 members of the association within three days of being notified. The State also pointed out that this resolution was appealed by SUNAT. 44. According to the State’s narrative, on July 24, 2006, the Sixth Civil Chamber of Lima decided the appeal lodged by SUNAT ordering a new accounting expert report on grounds that the expert accountant had followed erroneous criteria in determining the amounts owed. The State pointed out that this ruling ordered that the new expert report should be conducted in accordance with current legislation and existing jurisprudence in this area, and reiterated the incompatibility of adjusting pensions under the system established by Decree Law 20.530 based on the salary scales of the private sector system. 45. The State indicated that, in accordance with the previous decision, on October 25, 2006, a new expert report was ordered “with guidance from Article 3.c of Decree Law No. 673, given that the adjustment must be based on the salary scale of the active civil service employee or worker in Public Administration of the same rank and pay level that the retired employee held at the time of dismissal (…)”. 46. The State argued that these expert reports lacked legal grounds and veered away from the judicial rulings in this area because their implementation would mean that the Peruvian State would have to pay the members of the association amounts in the millions in pension 17