Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Page of 4883
Press 'Enter' after typing page number.
961 to 980 of 97649 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Reassessment founded solely on investigation material and statements already available during prior search assessment and revision proceedings constitutes reliance on stale material and a change of opinion. Repackaging existing information does not create fresh jurisdiction to reopen assessment. Where lender-company confirmations are obtained before issuing the reassessment notice but their responses are not addressed, the reopening lacks an adequate basis. Approval based on the same pre-existing material is mechanical and does not cure the jurisdictional defect. The reassessment proceedings and consequential additions were therefore deleted.
Reassessment founded solely on investigation material and statements already available during prior search assessment and revision proceedings constitutes reliance on stale material and a change of opinion. Repackaging existing information does not create fresh jurisdiction to reopen assessment. Where lender-company confirmations are obtained before issuing the reassessment notice but their responses are not addressed, the reopening lacks an adequate basis. Approval based on the same pre-existing material is mechanical and does not cure the jurisdictional defect. The reassessment proceedings and consequential additions were therefore deleted.
Note: It is a system-generated summary and is for quick reference only.