Prospective valuation amendment limits reassessment: unamended fair market value reference could not justify reopening based on a registered valuer's ...
Exemption for examination-related services rejected where recipients were commercial entities; suppression sustained extended limitation and penalties...
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Transfer pricing adjustment - Nature of amendment - prospective or retrospective - It does not make sense that someone tells you today as to how you should have behaved yesterday, and then goes on to levy a tax because you did not behave in that manner yesterday. - AT
Transfer pricing adjustment - Nature of amendment - prospective or retrospective - It does not make sense that someone tells you today as to how you should have behaved yesterday, and then goes on to levy a tax because you did not behave in that manner yesterday. - AT
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