Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Transfer pricing adjustments - selection of internal comparables - TPO had no mandate to have recourse to external comparables when in the present case, internal comparables were available, which could be applied for determining the ALP - AT
Transfer pricing adjustments - selection of internal comparables - TPO had no mandate to have recourse to external comparables when in the present case, internal comparables were available, which could be applied for determining the ALP - AT
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