CGT, APA, DTC, GAAR, Transfer Pricing cases. Prologue. Capital Gains Tax (CGT)CGT & Withholding norms (TDS)Vodafone CGTIT Act 1. Clarification (2. Direct Tax Code (DTC)DTC and Indirect transfers. Direct taxes: DTC vs. Budget- 2. 01. 4Tax Avoidance and GAARWhat is GAAR? Shome Panel on GAARWhat is Transfer Pricing?
Vodafone Transfer Pricing Issue. Budget 2. 01. 4: transfer pricing reforms. What is Advance Pricing Agreement? Roll back provision. Observe following photo. This is called withholding norms or Tax deduction at source (TDS).
Question: If income tax department doesn. Birla in Pantaloon deal and Vodafone in Hutch deal. Vodafone CGTHutchison (Hongkong) own a company called CGP investment Holding ltd, (Cayman Island)CGP owns 6.
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Hutch- Essar India. Vodafone (HQ London), tells its subsidiary in Netherland, to purchase Cayman Island Company from Hutch (Hongkong) for the price of 1. Now Vodafone owns CGP, therefore, and thus indirectly owns Hutch- Essar India also. Because CGP owned 6. Hutch Essar India.
Ok so what. So, he issues a clarification in IT act. IT Act 1. 96. 1: Clarification (2. We can demand Capital gains Tax, when a foreign company is sold. IF that foreign company. CGP valued at 5. 5k crore, because it owned Hutch. Essar India. Committee proposed changed. March. Chindu uploads revised (draft) Direct Tax Code 2.
Finance ministry website, to seek juntaa? Yes, because Economic survey 2. DTC. Budget 2. 01.
Jaitley said . Budget- 2. Comparision: Budget provisions vs DTC proposalstaxable income.
Budget 2. 01. 4DTC proposed. Wealth Tax,For assets above 3. Yes, but only on physical assets.
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Wealth tax on both: physical assets (gold, real estate etc)financial assets (shares, bonds, MF etc)DTC also provide plus higher slabs to senior citizens, and many other technical reforms. More on budget 2. They purchased an Indian company (Hutch- Essar) via purchasing an intermediary company (CGP) in a tax haven. Income tax act already has clear cut penalties for this. Income tax Act has grey areas, loopholes for this. Recall Supreme court ruled in favor of Vodafone because matter outside IT dept.
This money could have been used for financing fiscal deficit, inflation control, and Sarkaari schemes! Therefore, Government decided to make new rules to stop this menace. And, thus we come to next topic: What is GAAR?
General Anti Avoidance Rules. Originally mentioned in Budget 2. They were to be implemented from 1/4/2. IT commissioner take action against business deal made outside India, to avoid taxes. He can send notice to Indian Citizen, NRI, Foreigners, to recover such money: Even if they.
Company has to explain their deal is genuine. IT commissioner has to decide the case within 1. Aggrieved party can approach Dispute resolution Panel (DRP) => Income Tax Appellate Tribunal (ITAT) => HC and finally Supreme Court. GAAR not a completely new invention. China, Australia, Canada, New Zealand, Germany, France, S.
America etc already have similar concepts. Obviously MNCs wouldn. They lobbied hard, finally government setup a panel under Parthsarthi Shome Panel to review the GAAR rules.
Shome Panel on GAARRecommended following: IT commissioner should send notices only in rare cases- where he can recover more than 3 crore rupees. GAAR should not be used for filling revenue shortfalls. Revenue shortfall occurs when government. So in such cases, GAAR should not be used for extracting more money from corporates to finance Bogus Sarkaari schemes. For retrospective cases- only recover tax dues.
Better just increase the Securities Transaction Tax (STT) on buying/selling of such shares. Then, there is no litigation about . Problem permanently solved. Don. Implement it from April 2. For more GAAR features, pro and anti arguments click me. What would General Dong (Amrish Puri) sing for this gentleman? What happened after Shome?
Budget 2. 01. 3Chindu says we. New government yet to look at the issue in detail! These are also in context of Vodafone. What is Transfer Pricing? Recall the original concept of CGT & TDS: When a capital asset (shares) are transferred from seller (Kishor Biyani) to Buyer (K. M. Birla) => then Buyer has to withhold / deduct the capital gains tax for government.
Biyani and Birla are two unique businessmen / promoters. So, when share transferred from one person to another, we can hope the share price are decided by market forces of supply, demand and speculation. BUT WHAT IF two subsidiary companies transfer shares to each other, and play mischief. Vodafone Transfer Pricing Issue.
Vodafone London has two subsidiaries: Mauritius: Vodafone Teleservices India Holding Mauritius. India: (Call center) Vodafone India Services (VISPL)Two version. What Vodafone says? What IT Dept. 2. 50 crores. Mauritius arm says we bought shares to infuse new capital in the Indian arm. Real Market price of those shares = ~1.
Vodafone. Well Mauritius arm could sell those shares again to a third party at market price and make profit. So in a way, Mauritius will make . Case pending in Income Tax Appellate Tribunal (ITAT). Shell India, also caught in similar controversy.
Budget 2. 01. 4: transfer pricing reforms. Jaitley made new reforms in Budget 2. MNC confidence to invest in India. What is Advance Pricing Agreement? Advance pricing agreement (APA) is an agreement between: Tax payer (Vodafone)Tax authority (IT department)For deciding transfer price OR arm.
I can get you finest Vodka, Cognac and Champaign! IT commissioner. That. We only prefer Swadeshi. IF you want to operate in India, then you have to respect our culture (GS1) and tradition. Enough cheap jokes back to topic: APA concept introduced in Income Tax Act from 2. Ok then what is Jaitley.
For example: Inter- company price / Transfer price. Arm. Discuss advance pricing agreements, and their role in promoting foreign investment in India. Resulting into a lengthy litigation between Vodafone and Income tax department of India.
Government provided for advance pricing agreement in Income tax Act. APA is an agreement between tax payers and tax authorities. It validates the transfer pricing between two interrelated companies and ensures that it is equivalent to an arm’s length price. Government further reformed APA system, to provide . Now APA agreements can sort out pending litigations up to past four years using multi- year data analysis for share pricing.
Thus, APA is a win- win situation for both parties- tax authorities get their legitimate dues and companies become immune to future litigations. This clarity and continuity in tax policies will aid in bringing more foreign investment in India.(~1. Advance Tax ruling.
Jaitley also discussed this in budget- 2. This topic not directly related to Vodafone. But it. Started from 1. Retired SC judge and two government officials (of Addl. Secretary rank)Foreign company can file application to AAR, to seek clarification on its tax liabilities.(Fees: 2. Timeframe: AAR has to reply within 6 months.
AAR ruling binding on both company (Tax payer) and Income tax department. IT officials cannot send notices/raids if AAR already rules in advance that xyz matter is exempted. Timeframe: within 2 months. IT officials launch any fresh cases for retrospective tax demands, they. In this article, my purpose was to cover the bodies/reform that?
Does 3% education cess apply? Yes education cess applies. A2: What happened to Vodafone case? So far Vodafone is caught up in two cases. Hutch Essar CGTTransfer pricing of call centre. Government demanding ~2. CGT+interest+ penalty.
SC ruled in favor of Vodafone but Government brought clarification in IT act, to give retrospective notice. Government demanding ~3. In Dec 2. 01. 3, ITAT gave stay order for six months. In August 2. 01. 3, Chindu offered . And NOT at the call centre transfer pricing (Because that matter still pending.)I.
My first priority is to cover the.
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Heat Exchanger. Automobile Radiator. Source: Wikipedia via B Wrigley. The heat exchanger is a very important device used in many real world applications in which heat must be transferred from one medium to another. In many cases, the two mediums are separated by a solid wall, although in some cases the two mediums are in direct contact with each other, so that mixing occurs. For example, in some applications steam is injected into water in order to heat it up.
There are of course many more. The three types are: Parallel- flow or counterflow configuration, cross- flow configuration, and shell- and- tube configuration. Both figures show a simple concentric tube arrangement in which one of the fluids flows on the inner tube and the other fluid flows in the annular gap (between the tubes).
The figures show the hot fluid as being inside the inner tube, and the cold fluid as being inside the annular gap. In the parallel flow configuration both the hot and cold fluids flow in the same direction. In the counterflow configuration the fluids flow in opposite directions. These will be discussed in more detail later. Hence, cross- flow is often the preferred flow direction, and tends to be better than parallel flow or counterflow configurations.
Cross flow configurations are shown in the three figures below. The first figure shows cross flow over an unfinned array of tubes. The second and third figures show cross flow over a finned array of tubes, with square fins and circular fins (as shown). The purpose of fins is to increase heat transfer between the hot and cold mediums. This will be discussed in more detail later. One of the fluids flows through the inside of the shell and the other fluid flows through tubes passing through the inside of the shell, thereby enabling heat transfer between the two fluids. Baffles are added to enhance the convection coefficient, which increases heat transfer between the two fluids.
The baffles serve to induce turbulent mixing and a cross- flow component, both of which increase the convection coefficient. The first figure shows one shell pass and two tube passes. The second figure shows two shell passes and four tube passes.
The third figure shows a more detailed drawing of a shell- and- tube heat exchanger with one shell pass and one tube pass. It adds additional surface area, which enables additional heat flow to or from the medium the fin is in contact with, by way of convection.
To illustrate in quantitative terms the usefulness of a fin consider the following schematic showing a pin fin protruding out of a base surface at surface temperature Tb. A differential element of width dx is shown in orange.
It will be necessary to consider this element for the analysis that follows, which uses calculus. This is a valid assumption for steady state operating conditions. The right side of the above equation is the heat energy exiting the differential element. We get. Rearrange the above equation to give. Divide both sides of the above equation by dx. This gives us the final general differential equation for one- dimensional steady state heat transfer from an extended surface (given below). Using this equation we can solve for the temperature distribution T(x) given some set of boundary conditions.
But it is a reasonable simplification. Then, d. Ac(x)/dx = 0 in the above equation, and d.
As(x)/dx = P, where P is the perimeter (with As(x) = Px). The above equation then becomes. Since the above is a second order differential equation, we need two boundary conditions in terms of x to solve it. We can set the first boundary condition as T(0) = Tb.
For the second boundary condition we can assume negligible heat transfer at the tip, at x = L, so that q(L) = 0. This is a good assumption for a long fin, relative to its width, since the longer the fin is, the closer its tip temperature is to the ambient temperature T. By Fourier's law this means that the heat flow out of the tip approaches zero.
With this temperature distribution known we can solve for the heat transfer rate qf at the base of the fin (at x = 0). In the absence of the fin the heat transfer rate from the base is simply qb where. To see how much the fin increases heat transfer calculate the following ratio.
To illustrate by example, assume the pin fin is circular so that P = . Set d = 0. 0. 1 m, k = 1.
W/m. K, h = 5. 0 W/m. K, and L = 0. 1 m. The alternative way to increase heat transfer is by increasing h and/or decreasing T. Hence, adding fins makes more sense. For example, radiators (as shown in the first picture on this page) have many fins since it is the only way to enable the high rate of thermal energy exchange with the air. Note that despite the name, radiators generally transfer the bulk of their heat (with some medium, such as air) via convection, not by thermal radiation, so a more accurate name for them would be .
In fact, heat exchangers in general transfer the bulk of their heat via convection, and radiation heat transfer is usually negligible in comparison. This physically means that the temperature of the fin is closer to the base temperature Tb, along its length. In practical terms this means we want k as high as possible. Also, note that beyond a certain point, increases in L do not significantly increase the rate of heat transfer qf. This is because the farther you are along the fin, the closer the fin temperature T(x) is to T.
In this case fins will greatly aid in the transfer of heat to or from the object. If the convecting medium is a fluid, such as water, then h will generally be much higher and fins may not be necessary.
The mathematics of the solution does not change for either case. It just means that heat flows out of, or into the fin (respectively). For example, they can be pin fins protruding from a surface (as just described), or annular fins around a tube used to enhance heat flow into or out of the fluid flowing through the tube. The figure below illustrates such a fin. This can be accounted for by a fin correction factor, discussed in a later section on the overall heat transfer coefficient. Steady state flow is a valid assumption for steady operating conditions and temperatures. We treat the heat exchanger as insulated around the outside so that the only heat transfer is between the two fluids.
This differential element, of length dx and enclosed by dashed lines, is a control volume that is fixed in space). Th(x+dx) is the temperature of the hot fluid at position x+dx (right side of differential element 1). Tc(x) is the temperature of the cold fluid at position x (left side of differential element 2). Tc(x+dx) is the temperature of the cold fluid at position x+dx (right side of differential element 2). As is the differential area between differential elements 1 and 2. This differential area is located on the heat transfer surface (a wall) separating the hot and cold fluid streams. We can write the energy balance as.
The left side of the above equation is the energy entering the differential element. The right side of the above equation is the energy exiting the differential element. In the above equation thermal conduction along the axial (x) direction can be assumed negligible, and potential and kinetic energy changes are also assumed negligible. In this case it is reasonable to use an average value based on the average temperature of the hot fluid between the inlet and outlet.
It is necessary to make this distinction because in real flows the temperature can vary across the cross- section. Following the same procedure as before, we get. We treat it as constant, although it can vary as a result of temperature variations in the fluid. In this case it is reasonable to use an average value based on the average temperature of the cold fluid between the inlet and outlet.
Due to variations in fluid properties and flow conditions, U may vary over the flow length. However, in many applications such variations are not significant and one can reasonably assume a constant, and average value of U.