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TITLE Supreme Court Decision 2015Du39842 Decided July 20, 2018¡¼Revocation of Disposition Denying Petition for Correction¡½ [full Text]
Summary
Meaning of ¡°repudiation of wrongful calculation¡± as defined under Article 52 of the former Corporate Tax Act

Standard for determining the existence or absence of economic rationality

Whether the burden of allegation and proof as to ¡°market price¡± that serves as the standard for applying repudiation of wrongful calculation lies with the taxation authority (held: affirmative in principle)
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