Reopening assessments beyond four years requires nondisclosure of material facts; mere change of opinion or general allegations invalidates reassessme...
Directives address transfer pricing comparables and an ECB interest adjustment: three comparables newly available are to be included in the TP study and one additional comparable (previously directed) must be included; one comparable is to be excluded as functionally dissimilar because it serves specialized defence R&D activities unlike the taxpayer's telecom operations; an interest addition on unsecured related-party external commercial borrowing is deleted by application of the consistency principle since identical borrowings and interest were accepted in earlier years. Outcomes: include specified comparables, exclude the functionally dissimilar comparable, and delete the ECB interest adjustment.
Directives address transfer pricing comparables and an ECB interest adjustment: three comparables newly available are to be included in the TP study and one additional comparable (previously directed) must be included; one comparable is to be excluded as functionally dissimilar because it serves specialized defence R&D activities unlike the taxpayer's telecom operations; an interest addition on unsecured related-party external commercial borrowing is deleted by application of the consistency principle since identical borrowings and interest were accepted in earlier years. Outcomes: include specified comparables, exclude the functionally dissimilar comparable, and delete the ECB interest adjustment.
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