- No one in the world can take the place of your mother. Right or wrong, from her viewpoint you are always right. She may scold you for little things, but never for the big ones."
- You don't really understand human nature unless you know why a child on a merry-go-round will wave at his parents every time around - and why his parents will always wave back. ~William D. Tammeus
Tuesday, September 1, 2009
On Mother
Tuesday, August 18, 2009
In the month of June 2009 , i have been to Kolkota on official trip. it was a great trip and really I liked the city very much. I had a very different impression about the city ( only what Ihave got from old movies i.e. Amar prem, Do bhiga jameen etc. ) But it as pleasent surprise being there. I saw the New Bridge which in it self a good piece of morden time engeenering. But outsiders like me only know about Howarah bridge.
"Hath not a Jew Eyes"
To bait fish withal: if it will feed nothing else, it will feed my revenge. He hath disgrac'd me and hind'red me half a million; laugh'd at my losses, mock'd at my gains, scorned my nation, thwarted my bargains, cooled my friends, heated mine enemies.
And what's his reason? I am a Jew. Hath not a Jew eyes?Hath not a Jew hands, organs, dimensions, senses, affections,passions, fed with the same food, hurt with the same weapons,subject to the same diseases, healed by the same means, warmedand cooled by the same winter and summer, as a Christian is?
If you prick us, do we not bleed? If you tickle us, do we not laugh?If you poison us, do we not die? And if you wrong us, shall wenot revenge? If we are like you in the rest, we will resemble youin that. If a Jew wrong a Christian, what is his humility?Revenge. If a Christian wrong a Jew, what should his sufferancebe by Christian example? Why, revenge. The villaiy you teach me I will execute; and it shall go hard but I will better theinstruction.
--From The Merchant of Venice (III, i, 60-63)
To bait fish withal: if it will feed nothing else, it will feed my revenge. He hath disgrac'd me and hind'red me half a million; laugh'd at my losses, mock'd at my gains, scorned my nation, thwarted my bargains, cooled my friends, heated mine enemies.
And what's his reason? I am a Jew. Hath not a Jew eyes?Hath not a Jew hands, organs, dimensions, senses, affections,passions, fed with the same food, hurt with the same weapons,subject to the same diseases, healed by the same means, warmedand cooled by the same winter and summer, as a Christian is?
If you prick us, do we not bleed? If you tickle us, do we not laugh?If you poison us, do we not die? And if you wrong us, shall wenot revenge? If we are like you in the rest, we will resemble youin that. If a Jew wrong a Christian, what is his humility?Revenge. If a Christian wrong a Jew, what should his sufferancebe by Christian example? Why, revenge. The villaiy you teach me I will execute; and it shall go hard but I will better theinstruction.
--From The Merchant of Venice (III, i, 60-63)
Tuesday, February 24, 2009
Monday, December 8, 2008
Deemed dividend in case of closely held companies
DEEMED DIVIDEND
The concept of Deemed Dividend under the Income-tax Act, 1961(the Act) is not new. However, time and again many closely held company assessees and their controlling shareholders, to their surprise and dismay, realise very late the importance of this powerful taxing tool in the hands of the Assessing Officer.
The concept of Deemed Dividend is embedded in Section 2(22)(e) of the Income-tax Act, 1961 and was also embedded in section 2(6A)(e) of the Indian Income-tax Act, 1922. In nutshell, the concept envisages taxing certain payments made by closely held companies by way of loans or advances to certain shareholders of the company or to the concerns/companies in which they have substantial interest. Whenever any payment is made by way of loan or advance, the recipient of the loan or advance will be liable to be taxed on this amount as a dividend, to the extent to which the company has accumulated profits, under the deeming provisions of section 2(22)(e) although such loan or advance may have been given for genuine business purposes and even if the paying company may have received back the loan amount. Thus the section deems certain payments as dividend income which is not income under ordinary commercial parlance. Therefore,the name Deemed dividend.
The concept of deeming certain payments or loans or advances to substantial shareholders as income was introduced with the object of curbing tax evasion. Upto 31-5-1997 dividend was taxed in the hands of the recipient of the dividend. However many closely held companies never declared any dividend and accumulated profits in the company itself. Since no dividend was declared the same could not be taxed. However the companies did give loans or advances to substantial shareholders or to their concerns/companies who presumably enjoyed these funds but were not liable to pay any tax on the same as the amounts were loans or advances liable to be returned. These amounts of loans or advances are sought to be taxed as dividend by section 2(22)(e) of the Act by way of a deeming fiction..
Taxation of dividend under Income-tax Act, 1961 has undergone substantial changes in recent times. Effective from 1-6-1997 the scheme of taxation of dividend has been modified and is different from the old scheme . The essence of the old scheme was that the recipient of the dividend income was liable to pay the income-tax on the same, subject to certain exemptions. The new scheme essentially makes the dividend tax-free (section 10(33) of the Act) in the hands of the recipient (except cases covered under section 2(22(e)of the Act) and the dividend paying company has been made liable to pay tax on the amount of dividend declared , distributed or paid by it (Section 115-O of the Act). This tax is over and above the corporate income-tax which a company would normally pay. However there is no change in the scheme of taxation of Deemed Dividend contained in the section 2(22) (e) of the Act and such dividends are governed by the old scheme of taxation of dividend i.e. tax on deemed dividend is paid by the recipient and the paying company does not have to pay dividend tax but will be liable to deduct tax at source from such loans or advances/deemed dividend and pay the same to the Government.
The concept of Deemed Dividend under the Income-tax Act, 1961(the Act) is not new. However, time and again many closely held company assessees and their controlling shareholders, to their surprise and dismay, realise very late the importance of this powerful taxing tool in the hands of the Assessing Officer.
The concept of Deemed Dividend is embedded in Section 2(22)(e) of the Income-tax Act, 1961 and was also embedded in section 2(6A)(e) of the Indian Income-tax Act, 1922. In nutshell, the concept envisages taxing certain payments made by closely held companies by way of loans or advances to certain shareholders of the company or to the concerns/companies in which they have substantial interest. Whenever any payment is made by way of loan or advance, the recipient of the loan or advance will be liable to be taxed on this amount as a dividend, to the extent to which the company has accumulated profits, under the deeming provisions of section 2(22)(e) although such loan or advance may have been given for genuine business purposes and even if the paying company may have received back the loan amount. Thus the section deems certain payments as dividend income which is not income under ordinary commercial parlance. Therefore,the name Deemed dividend.
The concept of deeming certain payments or loans or advances to substantial shareholders as income was introduced with the object of curbing tax evasion. Upto 31-5-1997 dividend was taxed in the hands of the recipient of the dividend. However many closely held companies never declared any dividend and accumulated profits in the company itself. Since no dividend was declared the same could not be taxed. However the companies did give loans or advances to substantial shareholders or to their concerns/companies who presumably enjoyed these funds but were not liable to pay any tax on the same as the amounts were loans or advances liable to be returned. These amounts of loans or advances are sought to be taxed as dividend by section 2(22)(e) of the Act by way of a deeming fiction..
Taxation of dividend under Income-tax Act, 1961 has undergone substantial changes in recent times. Effective from 1-6-1997 the scheme of taxation of dividend has been modified and is different from the old scheme . The essence of the old scheme was that the recipient of the dividend income was liable to pay the income-tax on the same, subject to certain exemptions. The new scheme essentially makes the dividend tax-free (section 10(33) of the Act) in the hands of the recipient (except cases covered under section 2(22(e)of the Act) and the dividend paying company has been made liable to pay tax on the amount of dividend declared , distributed or paid by it (Section 115-O of the Act). This tax is over and above the corporate income-tax which a company would normally pay. However there is no change in the scheme of taxation of Deemed Dividend contained in the section 2(22) (e) of the Act and such dividends are governed by the old scheme of taxation of dividend i.e. tax on deemed dividend is paid by the recipient and the paying company does not have to pay dividend tax but will be liable to deduct tax at source from such loans or advances/deemed dividend and pay the same to the Government.
Tuesday, February 12, 2008
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