147Secondly, according to Ireland it cannot be claimed that the General Court committed a breach of procedure or failed to state reasons. The Court, which was not required to respond to every point made before it, did address the Commission’s arguments as to the role of Apple Inc.’s employees. As to the evidence about signing contracts, the admissibility of which is contested by the Commission, Ireland submits that this was only part of the evidence relied on by the Court to support its finding in paragraph 302 of the judgment under appeal. In any event, contrary to the Commission’s claim, an action for annulment cannot be based on information not provided during the administrative procedure, if that information was available at the time and should have been considered by the Commission (judgments of 20 September 2017, Commission v Frucona Košice, C‑300/16 P, EU:C:2017:706, paragraph 71, and of 22 May 2019, Real Madrid Club de Fútbol v Commission, T‑791/16, EU:T:2019:346, paragraph 118).
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