Tokyo Olympics: Organisers mulls to allow 20,000 fans for Tokyo 2020 Opening ceremony New sensation “Psychic” lion succesfully predicts four Euro matches Football Latest Sports News WTC Final LIVE Day 3: Covers still on but rain unlikely throughout Day 3 as India look to take charge against New Zealand by Taboolaby TaboolaSponsored LinksSponsored LinksPromoted LinksPromoted LinksYou May LikeSuresh Raina issues statement after arrest, says the incident in Mumbai was ‘unintentional’UndoIPL 2020 : Srikanth and fans slams MS Dhoni, says ‘wasted 15 Cr on Jadhav & Chawla’UndoShahid Afridi’s daughter Aqsa to marry Pakistan quick Shaheen AfridiUndoThe coaches have been strictly instructed to inform the WFI about any potential drug abuse by the athletes at the national camp. Any failure to report abuse will invoke suspension for the coaches.The WFI has circulated at notice to this effect. “In the recent years, Indian wrestling has been affected by three-four doping cases at the international level, which not only resulted in Indian wrestling being shamed globally but it also led to WFI paying heavy fines to the UWW. The WFI has, in fact, paid ₹ 32 lakhs in fine to the UWW for two of the country’s wrestlers returning positive for banned substances,” WFI chief Brij Bhushan Sharan Singh has stated in an advisory wrestlers attending national camps, all coaches and support staff.“Indian wrestlers alone can’t be blamed for doping, but the coaches and support staff attached with them at the national camp and during international events will equally have to take the blame for their failure to curb the doping menace. The coaches’ responsibility is not only restricted to imparting training to the wrestlers, but also to ensure that they remain dope free and don’t consume prohibited substances. WFI has decided that if any wrestler returns positive for doping at the camp or during international competitions, not only the wrestler but the attached coach and support staff will also be banned for an indefinite period. In fact, all the coaches and support staff members at the camp will be banned for their failure to stop doping. It’s important that all the wrestlers must be aware about doping and its consequences,” the notice added.Having been slapped with heavy penalties for Indian wrestlers indulgences in doping, the WFI resolved to hold all stakeholders – wrestlers, coaches and support staff – responsible for any suspected dope case.Also Read: UWW Level 1 courses in India attract over 70 participantsBajrang first Indian athlete to play at Madison Square Garden Wrestling Federation of India is setting new precedence not just in governance and commercialisation of the sports, but also in enforcing strict discipline and code.With an aim to cleanse the system and abolish the threat of doping, the Wrestling Federation of India will also hold the coaches and support staff responsible if a player is caught for doping. The liability and penalty shall not be restricted to the players, but the coach and support staff too will face severe action. Punitive majors include also a ban on the coach and support staff. Cricket Previous articleWatson thanked me for scoring quickly at the beginning before he got set: Du PlessisNext articleHockey India names 33 players for Jr Men’s National Coaching Camp Kunal DhyaniSports Tech enthusiast, he reports on Sports Tech industry and writes on sports products. RELATED ARTICLESMORE FROM AUTHOR Share on Facebook Tweet on Twitter Cricket ICC WTC Final: Ravichandran Ashwin reveals when he plans to retire from cricket Latest Sports NewsSports BusinessNewsSportSport NewsWrestling Euro 2020, Italy vs Wales LIVE: Gareth Bale and Co face do-or-die clash; Italy eye third consecutive win; Follow Live Updates, Cricket Sport News ATP Tour TAGSIndian WrestlingWFIWFI CoachWrestling CoachWrestling Federation of India SHARE YourBump15 Actors That Hollywood Banned For LifeYourBump|SponsoredSponsoredUndoDaily FunnyFemale Athlete Fails You Can’t Look Away FromDaily Funny|SponsoredSponsoredUndoDefinitionTime Was Not Kind To These 28 CelebritiesDefinition|SponsoredSponsoredUndoMaternity WeekA Letter From The Devil Written By A Possessed Nun In 1676 Has Been TranslatedMaternity Week|SponsoredSponsoredUndoPost FunThese Twins Were Named “Most Beautiful In The World,” Wait Until You See Them TodayPost Fun|SponsoredSponsoredUndoMisterStoryWoman Files For Divorce After Seeing This Photo – Can You See Why?MisterStory|SponsoredSponsoredUndo Cricket Cricket Facebook Twitter WFI: Coaches too will face action if wrestlers caught for doping Halle Open 2021 Final: Ugo Humbert vs Andrey Rublev, Head-to-Head, LIVE streaming; all you need to know Virat Kohli completes 10 years in Test Cricket: 10 things you should know about India skipper- check out By Kunal Dhyani – May 11, 2019 Tokyo Olympics: IOA fuming as Japan imposes stricter regulations on India’s Olympic team, calls it ‘discriminatory and unfair’ India Tour of Sri Lanka: From books to gym, Sanju Samson shares story of his quarantine life Football Happy Father’s Day: ‘We Miss You’, Hardik Pandya pens emotional message for his father
Our 6 ‘Best Buys Now’ Shares Simply click below to discover how you can take advantage of this. BP vs Premier Oil: which oil stock would I buy now? See all posts by Stuart Blair The high-calibre small-cap stock flying under the City’s radar Adventurous investors like you won’t want to miss out on what could be a truly astonishing opportunity…You see, over the past three years, this AIM-listed company has been quietly powering ahead… rewarding its shareholders with generous share price growth thanks to a carefully orchestrated ‘buy and build’ strategy.And with a first-class management team at the helm, a proven, well-executed business model, plus market-leading positions in high-margin, niche products… our analysts believe there’s still plenty more potential growth in the pipeline.Here’s your chance to discover exactly what has got our Motley Fool UK investment team all hot-under-the-collar about this tiny £350+ million enterprise… inside a specially prepared free investment report.But here’s the really exciting part… right now, we believe many UK investors have quite simply never heard of this company before! Stuart Blair | Tuesday, 5th January, 2021 | More on: BP HBR Image source: Getty Images. Click here to claim your copy of this special investment report — and we’ll tell you the name of this Top Small-Cap Stock… free of charge! Enter Your Email Address Renowned stock-picker Mark Rogers and his analyst team at The Motley Fool UK have named 6 shares that they believe UK investors should consider buying NOW.So if you’re looking for more stock ideas to try and best position your portfolio today, then it might be a good day for you. Because we’re offering a full 33% off your first year of membership to our flagship share-tipping service, backed by our ‘no quibbles’ 30-day subscription fee refund guarantee. I would like to receive emails from you about product information and offers from The Fool and its business partners. Each of these emails will provide a link to unsubscribe from future emails. More information about how The Fool collects, stores, and handles personal data is available in its Privacy Statement. Stuart Blair owns shares in BP. The Motley Fool UK has no position in any of the shares mentioned. Views expressed on the companies mentioned in this article are those of the writer and therefore may differ from the official recommendations we make in our subscription services such as Share Advisor, Hidden Winners and Pro. Here at The Motley Fool we believe that considering a diverse range of insights makes us better investors. Oil stocks were some of the worst performers among UK shares in 2020. This is due to the collapse of oil prices caused by the lack of demand. Worries also abound over the future of the oil industry, and BP (LSE: BP) believes that oil demand has already peaked. This has led to its ambitious renewable energy programme, announced last year.However, this is not the view held by everybody, and BP’s US counterpart, ExxonMobil, expects demand to climb until at least 2040. This is due to rising incomes and population. Is it therefore a good time to buy oil stocks, and if so, which one would I buy?5G is here – and shares of this ‘sleeping giant’ could be a great way for you to potentially profit!According to one leading industry firm, the 5G boom could create a global industry worth US$12.3 TRILLION out of thin air…And if you click here we’ll show you something that could be key to unlocking 5G’s full potential…Premier Oil will soon ‘disappear’Subject to shareholder approval, Premier Oil (LSE: PMO) is shortly going to be renamed Harbour Energy after a reverse takeover by private equity-backed Chrysaor. This means that Chrysaor will soon become a publicly traded company without the need to go through an IPO.As part of this deal, Premier’s stakeholders will own up to 23% of the enlarged group and current shareholders will hold only around 5.5%. It will also create the largest independent oil and gas company on the London Stock Exchange.Due to the tough environment for oil stocks at the moment, particularly smaller ones like Premier Oil, I believe this is a shrewd move. This is because it allows the company to pay off its large debt pile. The debt of over £2bn has held back the company for years, and previous plans to pay it off included issuing more shares and buying BP assets to generate more cash. I believe these had a number of problems and taking the tiny stake in Harbour Energy seems a preferable option.But while this makes Premier Oil a more tempting buy, I’m still not going for it. It may be a shrewd move for the firm, but the fact that Premier’s stake of the merger is extremely small means that it’s not worth a considerable amount for shareholders. With oil stocks currently under pressure, I also struggle to see the reformed company flourishing. I’m leaving it on the shelf for now.The oil stock I preferEven after the Deepwater Horizon oil spill in 2010, the BP share price was still higher than it is now. This highlights the pain inflicted on the firm throughout the pandemic. However, as a leading energy company worldwide, I still remain bullish on BP shares.Indeed, the company has already made “a commitment to return at least 60% of surplus cash to shareholders through share buybacks, once BP’s balance sheet has been de-leveraged”. This accompanies a dividend currently yielding around 6%. The BP share price therefore looks far too cheap to me right now.Of course, the company will face significant headwinds over the next few years. For example, BP’s debt is still too high and lockdowns around the world should continue to depress oil prices. But I believe that Bernard Looney is a competent leader and the renewable energy transition shows progress. Questions still remain over whether this will make BP more profitable, but I’m willing to take the risk.
Architects: Mahyar Architects Area Area of this architecture project Iran ShareFacebookTwitterPinterestWhatsappMailOrhttps://www.archdaily.com/939902/high-hopes-villa-mahyar-architects Clipboard Year: Photographs: DEED STUDIO Manufacturers Brands with products used in this architecture project 2019 Area: 765 m² Year Completion year of this architecture project High Hopes Villa / Mahyar ArchitectsSave this projectSaveHigh Hopes Villa / Mahyar Architects “COPY” Manufacturers: AutoDesk, Adobe, McNeelDesign Team:Mehdi Khani, Mahyar Arab BourbourClients:Masoud ShiraniLandscape:Mahyar Arab BourbourCollaborators:Bahram Arab, Alireza AlidustiCity:IsfahánCountry:IranMore SpecsLess SpecsSave this picture!© DEED STUDIORecommended ProductsWindowsC.R. LaurenceCRL-U.S. Aluminum Unit-Glaze SystemWindowsVitrocsaMinimalist Window – SlidingWoodSculptformTimber Click-on BattensDoorsdormakabaEntrance Doors – Revolving Door 4000 SeriesText description provided by the architects. Our lives are surrounded by our dreams; our time passes in the hope of having a future and turns into memories resulting in our days being filled with the joy of past memories and future hopes. The key idea of this project was inspired by the track “High Hopes” by Pink Floyd. On the other hand, the villa’s owner was very fond if the past and would enjoy reviewing the memories of the past. This interest of the contractor in the past reminded me of the track “High Hopes”, and consequently, I started designing.Save this picture!© DEED STUDIOSave this picture!Section DDSave this picture!© DEED STUDIOTo turn this idea to reality, we used two separate procedures for the plan and volume, and then, mixed the results. The key idea of the plan is the main lines of the River Zayande-Roud which turn into plan and landscape, and in the end, the final plan is divided into three main streams of past, present and future. The main idea of the volume was initially inspired by a combination of mountain which is the symbol of ambition and an arch in the old style which is the symbol of Persian architecture, which means a combination of the past and the future. This core has moved alongside an axis in six phases, trying to imply that our dreams, in contrast with the past, have always surrounded our lives.Save this picture!© DEED STUDIOAlso, in order to provoke a nostalgic feeling and to show the sweetness of our childhood, some symbols of old houses have been used which are in contrast with modern architecture. For example: Atrium or two-store gardens in old houses (Sunken Courtyard) The use of white, brown and green colors The use of bricks in the floor of the building, like old houses A platform for sitting and watching the outside of the building This project is situated in a recreational estate in the mountainous area of Chadgan in Isfahan, Iran.Save this picture!© DEED STUDIOSave this picture!Ground floor planSave this picture!© DEED STUDIOIt is located on the slope of a hill. It overlooks a lake and the city. On the other hand, this estate has some rules and regulations: The building cannot have a view from both sides The height of the building cannot be more than three meters from code zero The length of the yard in front of the building cannot be less than 12 meters There are shades installed at the spans, enabling the maximum and minimum use of sunshine during the summer and winter. Also, to provide the central areas of the building with sunlight, a glass atrium has been used.Save this picture!© DEED STUDIOThis building is equipped with natural air-conditioning, that is, natural airflow which is filtered by plants in front of the windows. The building spans are in the direction of natural airflow. The airflow becomes cool and pleasant as a result of passing over the plants that are placed in front of the windows. Every room has a window letting the air in and another window letting the air out. Atrium acts as a chimney, sucking the air in and letting it out.Save this picture!© DEED STUDIOProject gallerySee allShow lessTreehouse / PG AssociatesSelected ProjectsHouse With 3 Shed Roofs / 416 ArchitectsSelected Projects Share CopyHouses•Isfahán, Iran ArchDaily “COPY” High Hopes Villa / Mahyar Architects Houses Photographs Save this picture!© DEED STUDIO+ 30Curated by Hana Abdel Share ShareFacebookTwitterPinterestWhatsappMailOrhttps://www.archdaily.com/939902/high-hopes-villa-mahyar-architects Clipboard Projects CopyAbout this officeMahyar ArchitectsOfficeFollow#TagsProjectsBuilt ProjectsSelected ProjectsResidential ArchitectureHousesIsfahanOn FacebookIsfahánIranPublished on May 21, 2020Cite: “High Hopes Villa / Mahyar Architects” 20 May 2020. ArchDaily. Accessed 10 Jun 2021.
Howard Lake | 5 May 2004 | News Quarriers selects Burnett Works for strategic input Jackie Fowler, Managing Director of Burnett Works, explained more about thestrategy and its implementation. “April 2004 saw the start of a major three-year recruitment and retention programme for individuals which will include a testing programme across a whole range of media.” Quarriers, the social care charity in Scotland, has strengthened its partnership with Burnett Works by appointing thecommunications agency to produce and implement a three-year fundraising strategy.Burnett Works has already been responsible for designing the new visual identity for the charity, as well as a range of communications and fundraising campaigns.Quarriers is looking to increase significantly the income it receives from individual donors. Currently, annual income from fundraising is around the £2 million mark. But with only 14% of the charity’s income coming from individual supporters, this is seen as area of potential growth. Advertisement AddThis Sharing ButtonsShare to TwitterTwitterShare to FacebookFacebookShare to LinkedInLinkedInShare to EmailEmailShare to WhatsAppWhatsAppShare to MessengerMessengerShare to MoreAddThis 26 total views, 1 views today AddThis Sharing ButtonsShare to TwitterTwitterShare to FacebookFacebookShare to LinkedInLinkedInShare to EmailEmailShare to WhatsAppWhatsAppShare to MessengerMessengerShare to MoreAddThis Tagged with: Consulting & Agencies Individual giving About Howard Lake Howard Lake is a digital fundraising entrepreneur. Publisher of UK Fundraising, the world’s first web resource for professional fundraisers, since 1994. Trainer and consultant in digital fundraising. Founder of Fundraising Camp and co-founder of GoodJobs.org.uk. Researching massive growth in giving.
Home Indiana Agriculture News Indiana Farmers Look for the Heat to Return SHARE SHARE Facebook Twitter Previous articleFast Food Price Hikes Blamed on Corn-Based EthanolNext articleOhio State and Purdue Partner again at Farm Science Review Andy Eubank Facebook Twitter Indiana Farmers Look for the Heat to Return By Andy Eubank – Jul 30, 2013 West central crops goodThroughout the 2013 season David Virgin has benefitted from Mother Nature for the most part. As crops head into August Virgin says he would like it to warm up again, but there are no complaints from his farm in Montgomery County in the west-central part of Indiana.“We’ve been pleasantly blessed. Beans and corn have grown well. We’ve had rain when we needed it but the last couple of weeks our temperatures are cooler than normal. I think we dipped down to 49 degrees the other night, so good sleeping weather but not any good corn growing weather. We’re in the midst of deciding whether we want to do some fungicide or not. We’re pretty much all pollinated.”And on a truly positive note he added, “Sweet corn is excellent so if that counts for anything we might be headed for a good crop.”The crop dusting planes have been very busy spraying the last week in central Indiana and that does include Virgin’s area.“We’ve got some seed corn places around us and they’ve been hitting those hard and we’ve been finding everybody that has corn after corn they’ve been hitting that hard, and we’ve been watching ours. You know you think you should be having some gray leaf but we’re not seeing really telltale signs yet. I don’t know what it would take to really trigger it, but we are monitoring that pretty close.”In that part of Indiana pests haven’t been too problematic with a couple of exceptions, horseweeds and marestail. But those cooler temperatures are a concern.“We are actually now starting to work on some grain facilities that we normally wouldn’t bother because we’re feeling like we better get some dryer gas stored up because if we don’t continue to get our timely temperatures we could have a wet crop to get out.”Virgin has also traveled a good part of the Corn Belt in recent weeks and reports on what he saw in the complete HAT interview:David Virgin July 30 update
Previous: Millions May Lose Their Homes When Moratoria Expire Next: Key Takeaways from Real Estate in 2020 Servicers Navigate the Post-Pandemic World 2 days ago Print This Post 2020-12-17 Christina Hughes Babb in Daily Dose, Featured, Market Studies, News Data Provider Black Knight to Acquire Top of Mind 2 days ago Governmental Measures Target Expanded Access to Affordable Housing 2 days ago Sign up for DS News Daily The Best Markets For Residential Property Investors 2 days ago The Week Ahead: Nearing the Forbearance Exit 2 days ago The Best Markets For Residential Property Investors 2 days ago Christina Hughes Babb is a reporter for DS News and MReport. A graduate of Southern Methodist University, she has been a reporter, editor, and publisher in the Dallas area for more than 15 years. During her 10 years at Advocate Media and Dallas Magazine, she published thousands of articles covering local politics, real estate, development, crime, the arts, entertainment, and human interest, among other topics. She has won two national Mayborn School of Journalism Ten Spurs awards for nonfiction, and has penned pieces for Texas Monthly, Salon.com, Dallas Observer, Edible, and the Dallas Morning News, among others. Share 2Save Data Provider Black Knight to Acquire Top of Mind 2 days ago ‘Unusual Circumstances’ for the Home-Flipping Business December 17, 2020 1,752 Views Home / Daily Dose / ‘Unusual Circumstances’ for the Home-Flipping Business Servicers Navigate the Post-Pandemic World 2 days ago Demand Propels Home Prices Upward 2 days ago About Author: Christina Hughes Babb Governmental Measures Target Expanded Access to Affordable Housing 2 days ago Related Articles Demand Propels Home Prices Upward 2 days ago Real estate investors in the third quarter of 2020 have purchased and flipped 57,155 single-family homes and condominiums nationwide, according to the latest ATTOM Data Solutions Home Flipping Report.ATTOM researchers said that for the second consecutive quarter, the rate of house flipping is down, showing the lowest activity in four years, yet the typical investment returns have increased this quarter to the highest level since early 2018.Flips in Q3 represented 5.1% of home sales or one in 20 transactions. That’s down from 6.7% of all home sales last quarter (one in 15) and from 5.5% (one in 18 sales) in the third quarter of 2019.Gross profit on the typical home flip nationwide—that’s the difference between the median sales price and the median paid by investors—rose in the third quarter of 2020 to $73,766—the highest amount since at least 2000. That amount was up from $69,000 in the second quarter of 2020 and from $61,800 in the third quarter of last year, ATTOM reports.This increase caused profit margins to grow; the typical gross flipping profit was $73,766 in Q3 or a 44% ROI compared to the initial acquisition price.The gross flipping ROI is up—42,9% for the quarter and 40.3% from last year—for the second consecutive year following nine straight quarters of declines. from 42.9 percent in the second quarter of 2020 and 40.3 percent a year ago.The opposing trend that reveals lower flipping activity and higher profits reflects the broader housing market pattern—”Home prices kept soaring throughout most of the country in the third quarter as buyers—often seeking larger or more wide-open spaces—chased a dwindling supply of homes for sale,” ATTOM’s report reads.“Home-flipping again generated higher profits on less transactions across the United States in the third quarter of 2020 as investors continued to make more money on a declining number of deals,” said Todd Teta, Chief Product Officer at ATTOM. “This all happened in the context of the pandemic, which has created unusual circumstances for the housing market to thrive, and that has included the home-flipping business. Too much is uncertain these days to say whether the latest trends will continue. But for now, the prospects continue looking up for home flipping after a period when they were trending the opposite way.”ATTOM’s full report, which breaks down home flipping rates by region, is available on ATTOMdata.com. Subscribe
RELATED ARTICLESMORE FROM AUTHOR Google+ Facebook Pinterest Twitter Main Evening News, Sport and Obituaries Tuesday May 25th WhatsApp 365 additional cases of Covid-19 in Republic Previous articleEirgrid outline power plans for DonegalNext articlePublic urged to steer clear of Loan Sharks as Christmas nears News Highland By News Highland – December 4, 2009 News Twitter Facebook WhatsApp Donegal Deputy Dr James McDaid has indicated that he will follow through with a threat to vote against the government as early as in next weeks budget.Dr McDaid, who feels he is superfluous to Fianna Fail following an acrimonious local meeting, says he will not back the budget if it includes 12 days unpaid leave for public service workers.This comes as government and unions will make one last attempt today to conclude a deal on cutting the public service pay bill. Google+ 75 positive cases of Covid confirmed in North Deputy McDaid will vote against budget if required Man arrested on suspicion of drugs and criminal property offences in Derry Pinterest Further drop in people receiving PUP in Donegal Gardai continue to investigate Kilmacrennan fire
Top StoriesNo Income Tax Liability For UAE Exchange In India As Its Liaison Offices Are Not ‘Permanent Establishments’ Under DTAA : SC [Read Judgment] Mehal Jain26 April 2020 3:44 AMShare This – xIn a major tax relief to UAE Exchange, the Supreme Court has ruled that no income tax can be levied on its liaison offices in India in respect of the principal business carried by it in United Arab Emirates.Dismissing an appeal filed by the Income Tax Department against a judgment of the Delhi High Court, the SC held that no income is earned by the liaison offices in India. It was further…Your free access to Live Law has expiredTo read the article, get a premium account.Your Subscription Supports Independent JournalismSubscription starts from ₹ 599+GST (For 6 Months)View PlansPremium account gives you:Unlimited access to Live Law Archives, Weekly/Monthly Digest, Exclusive Notifications, Comments.Reading experience of Ad Free Version, Petition Copies, Judgement/Order Copies.Subscribe NowAlready a subscriber?LoginIn a major tax relief to UAE Exchange, the Supreme Court has ruled that no income tax can be levied on its liaison offices in India in respect of the principal business carried by it in United Arab Emirates.Dismissing an appeal filed by the Income Tax Department against a judgment of the Delhi High Court, the SC held that no income is earned by the liaison offices in India. It was further held that the liaison offices of UAE Exchange do not come within the meaning of “Permanent Establishment as per the provisions of the Income Tax Act, 1961 and the relevant Double Taxation Avoidance Agreements (DTAAs).A bench comprising Justices A M Khanwilkar and Ajay Rastogi held that UAE Exchange “was not carrying on any business activity in India as such, but only dispensing with the remittances by downloading information from the main server in UAE and printing cheques/drafts drawn on the banks in India as per the instructions given by the NRI remitters in UAE”.”The transaction(s) had completed with the remitters in UAE, and no charges towards fee/commission could be collected by the liaison office in India in that regard. To put it differently, no income as specified in Section 2(24) of the 1961 Act is earned by the liaison office in India and more so because, the liaison office is not a PE in terms of Article 5 of DTAA (as it is only carrying on activity of a preparatory or auxiliary character). The concomitant is – no tax can be levied or collected from the liaison office of the respondent in India in respect of the primary business activities consummated by the respondent in UAE”, the court held.The Court noted that the liaison offices were functioning in India based on the permissions granted by the Reserve Bank of India under the FERA, as per which UAE Exchange must steer away from engaging in any primary business activity and in establishing business connection as such. It can carry on activities of preparatory or auxiliary nature only.Therefore, the Court held that the deeming provisions in Sections 5 and 9 of the Income Tax Act Act regarding “accrual of income” in India are not attracted.The genesis of the dispute was the ruling given by the Authority for Advance Ruling in 2003 that “Income shall be deemed to accrue in India from the activity carried out by the liaison offices of UAE Exchange in India”For so holding, the Authority opined that in view of the deeming provision in Sections 2(24), 4 and 5 read with Section 9 of the 1961 Act, UAE Exchange would be liable to pay tax under the 1961 Act, as it had carried on business in India through a “permanent establishment” situated in India and the profits of the enterprise needed to be taxed in India, but only so much of that, as is attributable to the liaison offices in India (PE). Following this, the Income Tax department issued four assessment notices in 2004 with respect to four previous financial years. Challenging these notices, the UAE Exchange filed writ petition in the Delhi High Court.The HC allowed the writ petition holding that the liaison offices would not be PE as per the DTAA, and that the clauses of the DTAA will override the provisions of Income Tax Act. The DTAA between India and UAE had stated that PEs would be amenable to income tax. However, as per Article 5(3)(e) of the DTAA, “the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character”, will not constitute “PE”.Challenging the HC verdict, the department came in appeal before the SC.The SC observed that the nature of activities carried on by the respondent through the liaison office in India was in the nature of “preparatory or auxiliary character” and, therefore, covered by Article 5(3)(e) of the DTAA between India and UAE.”since the stated activities of the liaison offices of the respondent in India are of preparatory or auxiliary character, the same would fall within the excepted category under Article 5(3)(e) of the DTAA. Resultantly, it cannot be regarded as a PE within the sweep of Article 7 of DTAA”, the bench observed.In this regard, the Court specifically took note of the restrictions imposed by the RBI.”The conditions( of RBI) make it amply clear that the office in India will not undertake any other activity of trading, commercial or industrial, nor shall it enter into any business contracts in its own name without prior permission of the RBI. The liaison office of the respondent in India cannot even charge commission/fee or receive any remuneration or income in respect of the activities undertaken by the liaison office in India. From the onerous stipulations specified by the RBI, it could be safely concluded, as opined by the High Court, that the activities in question of the liaison office(s) of the respondent in India are circumscribed by the permission given by the RBI and are in the nature of preparatory or auxiliary character. That finding reached by the High Court is unexceptionable”.Section 9 IT Act not attractedThe SC also held that the deeming provision regarding accrual of income in India under Section 9 of the Income Tax Act was not attracted in the case.The bench observed in that regard as follows :”even if the stated activity(ies) of the liaison office of the respondent in India is regarded as business activity, as noted earlier, the same being “of preparatory or auxiliary character”; by virtue of Article 5(3)(e) of the DTAA, the fixed place of business (liaison office) of the respondent in India otherwise a PE, is deemed to be expressly excluded from being so. And since by a legal fiction it is deemed not to be a PE of the respondent in India, it is not amenable to tax liability in terms of Article 7 of the DTAA”Case DetailsTitle : Union of India vs UAE ExchangeCase No : Civil Appeal No. 9775 of 2011Coram : Justices A M Khanwilkar and Ajay RastogiAppearances : Senior Adv Arijit Prasad (for appellant) Adv H P Ranina for respondentClick here to download judgmentRead Judgment Subscribe to LiveLaw, enjoy Ad free version and other unlimited features, just INR 599 Click here to Subscribe. All payment options available.loading….Next Story