text:
Authority For Advance Rulings
E*trade Mauritius Ltd., In Re
Section 90, DTAA between India & Mauritius, Art. 13
P.V. Reddi, J., Chairman; J. Khosla, Member
AAR No. 826 of 2009
22nd March, 2010
Counsel Appeared :
S.E. Dastur with Madhur Agarwal, Sanjay Sanghvi, Ronak Ajmera & Mrs. Daksha Baxi, for the Applicant : G.C. Srivastava, for the CIT Concerned
P.V. Reddi, J., Chairman :
This application for advance ruling has been filed by a non-resident company under s. 245Q(1) of the IT Act. The following facts are stated in the application :
1.1 The applicant, E*Trade Mauritius Ltd. (âapplicantâ), is a company incorporated in Mauritius, holding a global business company licence issued by the financial services authority of Mauritius and is a tax resident of Mauritius. It has been issued a tax residency certificate by the Mauritius tax authorities. The applicant is a subsidiary of Converging Arrows Inc. USA which in turn is a subsidiary of E*Trade Financial Corporation, USA.
1.2 The applicant held equity shares in IL&FS Investsmart Ltd. (âIndian companyâ) which are listed on stock exchange in India. The applicant had acquired these shares in the years 2005, 2006 and 2007. The shares were acquired by way of direct purchases as well as upon conversion of the global depository receipts (“GDRs”) as per the details set out in Ext. âAâ. The applicant has transferred 30,625,692 shares in the Indian company to HSBC Violet Investment (Mauritius) Ltd., a company organized under the laws of Mauritius, at Rs. 200 per share on 29th Sept., 2008 and realized long-term capital gains thereon in India. A share purchase agreement was entered into on 16th May, 2008.
1.3 Being a tax resident of Mauritius, the applicant is governed by the provisions of the India-Mauritius DTAA in respect of its tax liability in India. As the provisions of the India-Mauritius DTAA are more beneficial, the provisions of that DTAA would be applicable, as specifically provided for in s. 90(2) of the IT Act. Further, during the period the applicant held shares in the Indian company, it did not have any permanent establishment (âPEâ) in India as defined in art. 5 of the India-Mauritius DTAA.
1.4 Upon sale of the said shares in the Indian company, the applicant had approached the Asstt. Director of IT, Mumbai to obtain the “nil” rate withholding tax certificate under s. 197 of the IT Act. The Asstt. Director of IT denied the request and determined that the capital gains tax of 21.11 per cent would be applied to the total sale consideration of the shares without deduction for the cost of acquisition. Being aggrieved by it, the applicant approached the Bombay High Court by way of a writ petition. The High Court, without going into the merits, directed the applicant to approach the Director of IT (International Taxation)(“Director of IT”) for a revision of the certificate under s. 264 of the IT Act and also directed HSBC Violet Investment (Mauritius) Ltd. to deposit an amount of rupees twenty-four crores and fifty lakhs with the Court until the disposal of the revision petition by the Director of IT. On 1st Jan., 2009, the Director of IT disposed of the revision petition. He concurred with the view of the Asstt. Director of IT that the transaction prima facie gave rise to a chargeable capital gains and upheld the denial of nil rate withholding certificate. He computed the capital gains tax liability of Rs. 24,31,05,710. The summary proceedings regarding issuance of tax deduction certificate thus ended with the issuance of the order of Director of IT.
1.5 The applicant has now approached this Authority to determine whether by virtue of being a Mauritius resident, it is eligible to the benefits of the India-Mauritius DTAA and hence not subject to tax in India on the capital gains realized.
2. The applicant has formulated the following questions for seeking advance ruling :
“(i) Whether on the stated facts and in law, the applicant, a tax resident of Mauritius, is exempt from payment of capital gains tax in India under the Double Taxation Avoidance Agreement (or “DTAA”) between India and Mauritius (“India-Mauritius DTAA”) in respect of the transfer of 30,625,692 shares in IL&FS Investmart Ltd. an Indian company to HSBC Violet Investments (Mauritius) Ltd ?”
(ii) If the answer to question (i) is in negative, whether on stated facts and in law, the applicant will be liable to pay tax on long-term capital gains at 10 per cent under the proviso to s. 112(1) of the IT Act, 1961 (“IT Act”) ?”
3. The contentious issue that arises for consideration is whether the profit arising from the transfer of shares of Indian company is chargeable to capital gains tax under the IT Act. The answer is plain. If we go by the IT Act, the profits arising from the transfer of shares are liable to be taxed under the head “Capital gains” at the appropriate rate. However, the position of taxability of capital gains is otherwise under the provisions of DTAA (tax treaty between India and Mauritius). To be more specific, art. 13, para 4 of the DTAA confers the power of taxation of the gains derived by a resident of a Contracting State from the alienation of specified property only in the State of residence i.e., in Mauritius. The fact that the capital asset is located in India is immaterial. In most of the treaties, we find that the situs or location of the capital asset determines the competence of the State to tax the capital gain. Yet, there is no doubt that the taxpayer is entitled in law to seek the benefit under the DTAA if the provision therein is more advantageous than the corresponding provision in the domestic law. This well-settled principle has been restated by the Supreme Court in the case of Union of India vs. Azadi Bachao Andolan & Anr. (2003) 184 CTR (SC) 450 : (2003) 263 ITR 706 (SC) a case which will be referred to hereinafter extensively. For the proposition which we have just now stated, the following passage in the said decision would suffice : “A survey of the aforesaid cases makes it clear that the judicial consensus in India has been that s. 90 is specifically intended to enable and empower the Central Government to issue a notification for implementation of the terms of a DTAA. When that happens, the provisions of such an agreement, with respect of cases to which where they apply, would operate even if inconsistent with the provisions of the IT Act. We approve of the reasoning in the decisions which we have noticed. If it was not the intention of the legislature to make a departure from the general principle of chargeability to tax under s. 4 and the general principle of ascertainment of total income under s. 5 of the Act, then there was no purpose in making those sections âsubject to the provisionsâ of the Act. The very object of grafting the said two sections with the said clause is to enable the Central Government to issue a notification under s. 90 towards implementation of the terms of the DTAAs which would automatically override the provisions of the IT Act in the matter of ascertainment of chargeability to income-tax and ascertainment of total income, to the extent of inconsistency with the terms of the DTAC.”
3.1 The contention of the respondents which weighed with the High Court, viz., that the impugned Circular No. 789 [(2000) 160 CTR (St) 5 : (2000) 243 ITR (St) 57] is inconsistent with the provisions of the Act, is a total non sequitur. As we have pointed out, Circular No. 789 is a circular within the meaning of s. 90; therefore, it must have the legal consequences contemplated by subs. (2) of s. 90. In other words, the circular shall prevail even if inconsistent with the provisions of the IT Act, 1961, insofar as assessees covered by the provisions of the DTAC are concerned.
4. Now, let us see the relevant provision in the DTAA i.e., art. 13 : “Article 13âCapital gains : Gains from the alienation of immovable property, as defined in para (2) of art. 6, may be taxed in the Contracting State in which such property is situated. Gains from the alienation of movable property forming part of the business property of a PE which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, including such gains from the alienation of such a PE (alone or together with the whole enterprise) or of such a fixed base, may be taxed in that other State. Notwithstanding the provisions of para (2) of this article, gains from the alienation of ships and aircraft operated in international traffic and movable property pertaining to the operation of such ships and aircraft, shall be taxable only in theContracting State in which the place of effective management of the enterprise is situated. Gains derived by a resident of a Contracting State from the alienation of any property other than those mentioned in paras (1),(2) and (3) of this article shall be taxable only in that State.”
4.1 Obviously and undisputedly, para 4 of art. 13 governs because the property alienated being shares in the company, does not fall under any of the preceding three paras. The applicant seeks to fortify its claim for non- liability to pay Indian income-tax on the strength of the tax residency certificate issued by the Mauritius Revenue Authority.
4.2 Thus far, there is no problem. The controversy has arisen on account of the stand taken by the Revenue. The stand of the Revenue is that there is scope and sufficient reason to infer that the capital gain from the transaction arises in the hands of the US entity which holds the applicant company. In other words, the beneficial ownership vests with the US company which according to the Department has played a crucial role in the entire transaction. Though the legal ownership ostensibly resides with the applicant, the real and beneficial owner of the capital gains is the US company which controls the applicant and the applicant company is merely a faÃ§ade made use of by the US holding company to avoid capital gains tax in India. It is pointed out that in the order passed under s. 264 of the IT Act, the Director of IT has taken a prima facie view that the capital gains is taxable in the hands of the US entity. Certain aspects were pointed out to conclude that there was sufficient justification to make further enquiries to arrive at the finding as who is really the beneficial owner of the gains. Though certain details have been ascertained from the applicant, still some more enquiries are necessary to unravel the correct facts as regards the source of funds, treatment of shareholdings, the manner of accounting and the role played by the US company in the deal. It is, therefore, inappropriate at this stage to give a ruling on the questions raised by the applicant, according to the Revenueâs counsel. It has been clarified in the course of arguments that the Department has not come to a definite conclusion, but such a conclusion could only be reached after fuller investigation. It is pointed out that if the Department comes to the conclusion that the beneficiary and real owner of the capital gains arising from the transfer of shares is the US holding company, the Indo-USA tax treaty governs in which case the tax liability under the IT Act will be fastened on the US company. The relevant article in India USA treaty is as follows :
“Article 13âGains : Except as provided in art. 8 â¦, each Contracting State may tax capital gains in accordance with the provisions of its domestic law.”
4.3 In reply to the stand taken by the Department the learned senior counsel for the applicant contended that beneficial ownership is really irrelevant in the context of art. 13. In contrast, such expression is used in arts. 10 and 11. In any case, it is submitted that the applicant has already furnished the information required by the Revenue at the stage of s. 264 proceedings and filed before the AAR all the relevant material and clarifications to dispel the doubts entertained by Revenue. In fact, the enquiry is a futile and wholly unnecessary exercise in view of the clear circular of CBDT which is binding on the Department and the law clarified by the Supreme Court in Azadi Bachao Andolan case (supra).
4.4 Thus, strong reliance has been placed on behalf of the applicant on the two circulars issued by the Central Borad of Direct Taxes (CBDT) and the decision of the Supreme Court in Azadi Bachao Andolan case (supra). First we shall refer to those circulars : “Circular No. 682, dt. 30th March, 1994 [(1994) 118 CTR (St) 1] :
Subject : Agreement for avoidance of double taxation with MauritiusâClarification regarding. A Convention for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes of income and capital gains was entered into between the Government of India and the Government of Mauritius and was notified on 6th Dec., 1983. In respect of India, the convention applies from the asst. yr. 1983-84 and onwards. Article 13 of the convention deals with taxation of capital gains and it has five paras. The first para gives the right of taxation of capital gains on the alienation of immovable property to the country in which the property is situated. The second and third paras deal with right of taxation of capital gains on the alienation of movable property linked with business or profession enterprises and ships and aircrafts. Para 4 deals with taxation of capital gains arising from the alienation of any property other than those mentioned in the preceding paras and gives the right of taxation of capital gains only to that State of which the person deriving the capital gains is a resident. In terms of para 4, capital gains derived by a resident of Mauritius by alienation of shares of companies shall be taxable only in Mauritius according to Mauritius tax law. Therefore, any resident of Mauritius deriving income from alienation of shares of Indian companies will be liable to capital gains tax only in Mauritius as per Mauritius tax law and will not have any capital gains tax liability in India. Para 5, defines âalienationâ to mean the sale, exchange transfer or relinquishment of the property or the extinguishment of any right in it or its compulsory acquisition under any law in force in India or in Mauritius. (Sd.) Secretary, CBDT”
4.5 Circular No. 789, dt. 13th April, 2000 : “Subject : Clarification regarding taxation of income from dividends and capital gains under the Indo-Mauritius Double Tax Avoidance Convention (DTAC)âRegarding The provisions of the Indo-Mauritius DTAC of 1983 apply to âresidentsâ of both India and Mauritius. Article 4 of the DTAC defines a resident of one State to mean âany person who, under the laws of that State is liable to taxation therein by reason of his domicile, residence, place of management or any other criterion of a similar nature.â Foreign institutional investors and other investment funds, etc., which are operating from Mauritius are invariably incorporated in that country. These entities are âliable to taxâ under the Mauritius tax law and are, therefore, to be considered as residents of Mauritius in accordance with the DTAC. 2. Prior to 1st June, 1997, dividends distributed by domestic companies were taxable in the hands of the shareholder and tax was deductible at source under the IT Act, 1961. Under the DTAC, tax was deductible at source on the gross dividend paid out @ 5 per cent or 15 per cent depending upon the extent of shareholding of the Mauritius resident. Under the IT Act, 1961, tax was deductible at source at the rates specified under s. 115A, etc. Doubts have been raised regarding the taxation of dividends in the hands of investors from Mauritius. It is hereby clarified that wherever a certificate of residence is issued by the Mauritian authorities, such certificate will constitute sufficient evidence for accepting the status of residence as well as beneficial ownership for applying the DTAC accordingly. The test of residence mentioned above would also apply in respect of income from capital gains on sale of shares. Accordingly, FIIs, etc. which are resident in Mauritius should not be taxable in India on income from capital gains arising in India on sale of shares as per para 4 of art. 13. The aforesaid clarification shall apply to all proceedings which are pending at various levels.” In the course of hearing, the learned counsel for the Revenue has stated that the residential status and the application of benefits of India Mauritius treaty is not in dispute. Further, Revenue is not taking any stand which goes against the Circular No. 789 issued by the CBDT. However, it is contended that the terminology âbeneficial ownershipâ referred to in the circular was used in the circular in the context of the article dealing with dividends and it shall be confined only to dividends. Therefore, as far as beneficial ownership vis-a-vis capital gains is concerned, the circular cannot be relied on by the applicant. The learned counsel for the Revenue then clarified that Revenue is not seeking to argue that the treaty benefit should be denied merely because the applicant is controlled and managed by the US entities or that the financial assistance was extended by the holding company for acquisition of shares. It is pointed out that the Revenueâs case is that despite setting up a subsidiary in Mauritius, if US holding company factually does the business in India and exercises rights of ownership in shares, the US entity cannot get out of tax net. What the US entity is doing in India can be the subject-matter of inquiry and the IT authority is not inhibited to undertake such inquiry. Among other things, it is submitted that the inquiry can be made into the question whether the US company directly appropriated the income from the transfer of shares or it went into to the profits of the applicant company. If it is latter, there can possibly be no objection. In short, it is submitted that ownership is a question of fact and it is only after inquiry, it will be known whether the apparent is real. From the mere fact that the receipts are reflected in the books of account, it does not follow that the inquiry is precluded to identify the entity to whom the gains actually belong to. Referring to Azadi Bachao case (supra), it is submitted that the question of colourable device still survives for consideration and the Revenue can very well examine whether the real nature of transaction is different from what it purports to be. The background in which the circulars were issued has been indicated in Azadi Bachao Andolan case (supra) at p. 716 of ITR thus : “By Circular No. 682, dt. 30th March, 1994 [(1994) 118 CTR (St) 1 : (1994) 207 ITR (St) 7] issued by the CBDT in exercise of its powers under s. 90 of the Act, the Government of India clarified that capital gains of any resident of Mauritius by alienation of shares of an Indian company shall be taxable only in Mauritius according to Mauritius taxation laws and will not be liable to tax in India. Relying on this, a large number of foreign institutional investors (hereinafter referred to as âthe FIIsâ), which were resident in Mauritius, invested large amounts of capital in shares of Indian companies with expectations of making profits by sale of such shares without being subjected to tax in India. Some time in the year 2000, some of the IT authorities issued show-cause notices to some FIIs functioning in India calling upon them to show cause as to why they should not be taxed for profits and dividends accrued to them in India. The basis on which the show-cause notice was issued was that the recipients of the show-cause notice were mostly âshell companiesâ incorporated in Mauritius, operating through Mauritius, whose main purpose was investment of funds in India. It was alleged that these companies were controlled and managed from countries other than India or Mauritius and as such they were not âresidentsâ of Mauritius so as to derive the benefits of the DTAC. These show-cause notices resulted in panic and consequent hasty withdrawal of funds by the FIIs. The Indian Finance Minister issued a press note dt. 4th April, 2000 clarifying that the views taken by some of the ITOs pertained to specific cases of assessment and did not represent or reflect the policy of the Government of India with regard to denial of tax benefits to such FIIs. Thereafter, to further clarify the situation, the CBDT issued Circular No. 789, dt. 13th April, 2000. Since this is the crucial circular, it would be worthwhile reproducing its full text.”
6.1 On the scope and validity of the circular, the learned Judges said : “As early as on 30th March, 1994, the CBDT had issued Circular No. 682 [(1994) 118 CTR (St) 1 : (1994) 207 ITR (St) 7] in which it had been emphasized that any resident of Mauritius deriving income from alienation of shares of an Indian company would be liable to capital gains tax only in Mauritius as per Mauritius tax law and would not have any capital gains tax liability in India. This circular was a clear enunciation of the provisions contained in the DTAC, which would have overriding effect over the provisions of ss. 4 and 5 of the IT Act, 1961 by virtue of s. 90(1) of the Actâ¦.”
6.2 It may be noted that the Circular No. 789 of the year 2000 was quashed by the Delhi High Court in a public interest litigation initiated under Art. 226 of the Constitution of India. The High Court, inter alia, held (i) in as much as the impugned circular directs the IT authorities to accept a certificate of residence issued by the authorities of Mauritius as sufficient evidence of the status of resident and beneficial ownership, it is ultra vires the powers of the CBDT, (ii) the ITO is entitled to lift the corporate veil in order to see whether or not a company is actually a resident of Mauritius paying income-tax in Mauritius; as this function is quasi judicial in nature, the CBDT cannot interfere with the exercise of that power, (iii) conclusiveness of a certificate of residence issued by Mauritius IT authorities is not contemplated either under the DTAA or under the IT Act, (iv) âtreaty shoppingâ by which the resident of a third country takes advantage of the provision of the DTAC is illegal, (v) the circular confers power to lay down a law which is not contemplated under the Act for reasons of political expediency and, therefore, it cannot but be ultra vires , (vi) having regard to the law laid down by the Supreme Court in McDowell & Co. Ltd. vs. CTO (1985) 47 CTR (SC) 126 : (1985) 154 ITR 148 (SC) case , it is open to the ITO in a given case to lift the corporate veil for finding out whether the purpose of the corporate veil is avoidance of tax or not, (vii) the impugned circular takes away the power of the assessing authority to hold that the assessee is a resident of a third country having only paper existence in Mauritius without any economic impact with the sole object of taking advantage of DTAC and is therefore illegal.
6.3 The Supreme Court expressed its disagreement with all these findings of the High Court and reversed the decision of the High Court and upheld the Circular No. 789. The circular was strongly supported by the Union of India which challenged the decision of the High Court in the Supreme Court.
6.4 At the risk of repetition, the crucial part of the circular is extracted below : “Doubts have been raised regarding the taxation of dividends in the hands of investors from Mauritius. It is hereby clarified that wherever a certificate of residence is issued by the Mauritian authorities, such certificate will constitute sufficient evidence for accepting the status of residence as well as beneficial ownership for applying the DTAC accordingly. The test of residence mentioned above would also apply in respect of income from capital gains on sale of shares. Accordingly, FIIs, etc. which are resident in Mauritius should not be taxable in India on income from capital gains arising in India on sale of shares as per para 4 of art. 3 of DTAC.”
6.5 The learned counsel for the Revenue attempted to draw some subtle distinctions to make out the point that the circular is to be confined only to dividends and secondly the aspect of beneficial ownership is not to be found in the third para of the circular dealing with the capital gains. We do not think that there is any substance in this contention. There is nothing in the language of the circular to support the contention. As seen from the âsubjectâ, the circular purports to give clarification both in respect of dividends and capital gains. May be, as pointed out by the counsel for Revenue, the reason for issuing the circular was to give quietus to certain doubts raised regarding the taxation of dividends turning on the residential status, but, it is crystal clear that the circular also applies in respect of income from capital gains arising from sale of shares of Indian companies. Both paras 2 and 3 of the circular shall be read together. It seems to be an untenable proposition to say that as far as capital gains is concerned, a certificate of residence will not be relevant to determine the beneficial ownership of the gains, but it would only be relevant for the purpose of dividend income. If a resident of Mauritius who gets dividends from the shares is considered to be beneficial owner thereof, there is no rational reason to view the ownership of gains arising from their transfer on a different footing. Of course, a doubt does arise as to why the residence or the certificate of residence is made a determining factor to infer beneficial ownership. Is there inextricable nexus between the two ? These doubts, though linger in our minds, should however not impel us to question the wisdom or rationale behind the clarification given in the circular especially when it has received the seal of approval of the Supreme Court in Azadi Bachao (supra) on all aspects.
7. Apart from considering the validity of the circular, the Supreme Court examined various aspects revolving round the avoidance of tax by Mauritian business entities set up by the holding companies in other countries for the purpose of taking advantage of India-Mauritius DTAC. In the context of the arguments advanced by the Revenue, the views expressed by the Supreme Court on these various aspects such as the motive and device adopted to avoid the tax, treaty shopping, lifting the corporate veil, the import of the expressions âshamâ and âdeviceâ, the implications of McDowell’s case (supra) deserve serious attention. We would like to refer to the pertinent observations made by the learned Judges rather extensively.
7.1 At p. 753, the Supreme Court referred to the argument of the respondent based on the dicta of Chinnappa Reddy, J, in McDowell’s case (supra), repelled the same and reiterated the well-settled principles on tax planning and avoidance of tax by means open to a subject under law.
7.2 At p. 753 it was observed : “There are many principles in fiscal economy which, though at first blush might appear to be evil, are tolerated in a developing economy, in the interest of long-term development. Deficit financing, for example, is one; treaty shopping, in our view, is another. Despite the sound and fury of the respondents over the so-called âabuseâ of âtreaty shoppingâ, perhaps, it may have been intended at the time when the Indo-Mauritius DTAC was entered into. Whether it should continue, and, if so, for how long, is a matter which is best left to the discretion of the executive as it is dependent upon several economic and political considerations. This Court cannot judge the legality of treaty shopping merely because one section of thought considers it improper. The respondents strenuously criticized the act of incorporation by FIIs under the Mauritian Act as a âshamâ and âa deviceâ actuated by improper motives. They contend that this Court should interdict such arrangements and, as if by waving a magic wand, bring about a situation where the incorporation becomes non est. For this they heavily rely on the judgment of the Constitution Bench of this Court in McDowell & Co. Ltd. vs. CTO (1985) 47 CTR (SC) 126 : (1985) 154 ITR 148 (SC). Placing strong reliance on McDowellâs case (supra) it is argued that McDowellâs case (supra) has changed the concept of fiscal jurisprudence in this country and any tax planning which is intended to and results in avoidance of tax must be struck down by the Court. Considering the seminal nature of the contention, it is necessary to consider in some detail as to why McDowellâs case (supra), what it says, and what it does not say.”
7.3 At p. 754, the dicta of Lord Tomlin in IRC vs. Duke of West Minster (1936) AC 1 (HL) was quoted with approval. We are quoting the same : “Every man is entitled if he can to order his affairs so that the tax attaching under the appropriate Acts is less than it otherwise would be. If he succeeds in ordering them so as to secure this result, then, however, unappreciative the IRCs or his fellow taxpayers may be of his ingenuity, he cannot be compelled to pay an increased tax.”
7.4 In the next para, it was said in Azadi Bachao case (supra) : “These were the pre-second world war sentiments expressed by the British Courts. It is urged that McDowellâs case has taken a new look at fiscal jurisprudence and âthe ghost of Fisherâs case (1926) AC 395 at 412 (HL) and Westminsterâs case (1936) AC 1 (HL) have been exorcised in the country of its originâ. It is also urged that McDowell & Co. Ltd. vs. CTO (1985) 47 CTR (SC) 126 : (1985) 154 ITR 148 (SC) radical departure was in tune with the changed thinking on fiscal jurisprudence by the English Courts. As we shall show presently, far from being exorcised in its country of origin, Duke of Westminsterâs case (1936) AC 1 (HL) : 19 Tax Cases 490 continues to be alive and kicking in England. Interestingly, even in McDowellâs case (supra), though Chinnappa Reddy, J. dismissed the observation of J.C. Shah, J. in CIT vs. A. Raman & Co. (1968) 67 ITR 11 (SC) based on Westminsterâs case and Fisherâs Executors case (1926) AC 395 at 412 (HL), by saying (p. 160 of 154 ITR) âwe think that the time has come for us to depart from the Westminister principle as emphatically as the British Courts have done and to dissociate ourselves from the observations of Shah, J., and similar observations made elsewhereâ, it does not appear that the rest of the learned Judges of the Constitutional Bench contributed to this radical thinking.”
7.5 Further, criticizing the opinion of Chinnappa Reddy, J. in Mc Dowellâs case the learned Judges observed : “the basic assumption made in the judgment of Chinnappa Reddy, J. in McDowellâs case that the principle in Duke of West Minster has been departed from subsequently by the House of Lords in England, with respect, is not correct.” Then, the decision of House of Lords in Craven (Inspector of Taxes) vs. White (Stephen) (1990) 183 ITR 216 (HL) was referred to. The opinion of Lord Keith in the following passage is quite apposite for our purpose : “In our view the proper way to construe a taxing statute, while considering a device to avoid tax, is not to ask whether a provision should be construed literally or liberally nor whether the transaction is not unreal and not prohibited by the statute, but whether the transaction is a device to avoid tax, and whether the transaction is such that the judicial process may accord its approval to it. The principle does not involve, in my opinion, that it is part of the judicial function to treat as nugatory any step whatever which a taxpayer may take with a view to the avoidance or mitigation of tax. It remains true in general that the taxpayer, where he is in a position to carry through a transaction in two alternative ways, one of which will result in liability to tax and the other of which will not, is at liberty to choose the latter and to do so effectively in the absence of any specific tax avoidance provision such as s. 460 of the Income and Corporation Taxes Act, 1970.”
7.6 After elaborate discussion on the above points, the Supreme Court observed at p. 758 :
“With respect, therefore, we are unable to agree with the view that Duke of Westminsterâs case (1936) AC 1 (HL) : 19 Tax Cases
490 is dead, or that its ghost has been exorcised in England. The House of Lords does not seem to think so, and we agree, with respect. In our view, the principle in Duke of Westminsterâs case (supra) is very much alive and kicking in the country of its birth. And as far as this country is concerned, the observations of Shah, J. in CIT vs. A. Raman & Co. (1968) 67 ITR 11 (SC) are very much relevant even today.”
7.7 However, in Azadi Bachao (supra), the Supreme Court referred to the opinion of Ranganath Misra, J. speaking for the majority [in McDowellâs case (supra)] to the effect that “tax planning may be legitimate provided it is within the framework of law. Colourable devices cannot be part of tax planning and it is wrong to encourage or entertain the belief that it is honourable to avoid the payment of tax by resorting to dubious methods”.Immediately thereafter, the learned Judges commented that this opinion of the majority is a “far cry from the view of Chinnappa Reddy, J.” who spoke in the following words : “In our view the proper way to construe a taxing statute, while considering a device to avoid tax, is not to ask whether a provision should be construed literally or liberally nor whether the transaction is not unreal and not prohibited by the statute, but whether the transaction is a device to avoid tax, and whether the transaction is such that the judicial process may accord its approval to it.” Then, the learned Judges in Azadi Bachao (supra) commented : “We are afraid that we are unable to read or comprehend the majority judgment in McDowellâs case as having endorsed this extreme view of Chinnappa Reddy, J., which in our considered opinion, actually militates against the observations of the majority of the Judges which we have just extracted.”
7.8 In Azadi Bachao case (supra), the learned Judges also referred to the judgment of the Gujarat High Court in Banyan & Berry vs. CIT (1996) 131 CTR (Guj) 127 : (1996) 222 ITR 831 (Guj) and quoted the following passage :”The facts and circumstances which lead to McDowellâs decision leave us in no doubt that the principle enunciated in the above case has not affected the freedom of the citizen to act in a manner according to his requirements, his wishes in the manner of doing any trade, activity or planning his affairs with circumspection, within the framework of law, unless the same fall in the category of colourable device which may properly be called a device or a dubious method or a subterfuge clothed with apparent dignity.” Then, it was observed that “this accords with our own view in the matter”.
7.9 Explaining the words âshamâ and âdeviceâ, it was observed at p. 761 : “Though the words âshamâ, and âdeviceâ were loosely used in connection with the incorporation under the Mauritius law, we deem it fit to enter a caveat here. These words are not intended to be used as magic mantras or catch-all phrases to defeat or nullify the effect of a legal situation.” In the previous para, the learned Judges also referred to the decision in Barber-Greene Americas Inc. vs IRC 35 Tax Cases 365 para wherein it was observed that : “A corporation will not be denied Western Hemisphere trade corporation tax benefits merely because it was purposely created and operated in such way as to obtain such benefits. Similarly, a corporation otherwise qualified should not be disregarded merely because it was purposely created and operated to obtain the benefits of the United States-Swiss Confederation income-tax Convention.” Then, the following observations of Lord Tomlin in Duke of West Minsterâs case (supra) were quoted with approval : “There may, of course, be cases where documents are not bona fide nor intended to be acted upon, but are only used as a cloak to conceal a different transaction.”
8. At p. 763, the proposition was emphatically stated thus : “We are unable to agree with the submission that an act which is otherwise valid in law can be treated as non est merely on the basis of some underlying motive supposedly resulting in some economic detriment or prejudice to the national interests, as perceived by the respondents.”
8.1 The legal position was summed up as follows at p. 762 : “If the Court finds that notwithstanding a series of legal steps taken by an assessee, the intended legal result has not been achieved, the Court might be justified in overlooking the intermediate steps, but it would not be permissible for the Court to treat the intervening legal steps as non est based upon some hypothetical assessment of the âreal motiveâ of the assessee. In our view, the Court must deal with what is tangible in an objective manner and cannot afford to chase a will-oâthe-wisp.”
8.2 Earlier, the learned Judges quoted several judgments to reinforce their view that the motive of tax avoidance is irrelevant in considering the legal efficacy of a transaction.
9. Now, we shall refer to the relevant passages in Azadi Bachao Andolan case (supra) dealing with âtreaty shoppingâ. âTreaty shoppingâ broadly means “the use of a tax treaty by a person who is not resident in either of the treaty countries, usually using a conduit entity residing in one of the countries”. [see Glossary of International Tax TermsâAppendix to Vol. I of Basic International Taxation by Mr. Roy Rohtagi].
9.1 The following passages at pp. 746, 749 and 752 may be noted : “The respondents vehemently urge that the offshore companies have been incorporated under the laws of Mauritius only as shell companies, which carry on no business therein, and are incorporated only with the motive of taking undue advantage of the DTAC between India and Mauritius. They also urged that âtreaty shoppingâ is both unethical and illegal and amounts to a fraud on the treaty and that this Court must be astute to interdict all attempts at treaty shopping. âTreaty shoppingâ is a graphic expression used to describe the act of a resident of a third country taking advantage of a fiscal treaty between two Contracting States. We are afraid that the weighty recommendations of the working group on non- resident taxation are again about what the law ought to be, and a pointer to Parliament and the executive for incorporating suitable limitation provisions in the treaty itself or by domestic legislation. This per se does not render an attempt by a resident of a third country to take advantage of the existing provisions of the DTAC illegal. Many developing countries tolerate or encourage treaty shopping, even if it is unintended, improper or unjustified, for other non-tax reasons, unless it leads to a significant loss of tax revenues. Moreover, several of them allow the use of their treaty network to attract foreign enterprises and offshore activities. Some of them favour treaty shopping for outbound investment to reduce the foreign taxes of their tax residents but dislike their own loss of tax revenues on inbound investment or trade of non-residents. In developing countries, treaty shopping is often regarded as a tax incentive to attract scarce foreign capital or technology. They are able to grant tax concessions exclusively to foreign investors over and above the domestic tax law provisions. In this respect, it does not differ much from other similar tax incentives given by them, such as tax holidays, grants, etc. (see Roy Rohtagi, Basic International Taxation, pp. 373-374. Developing countries need foreign investments, and the treaty shopping
opportunities can be an additional factor to attract them.” The other relevant passages at p. 753, we have already quoted earlier.
9.2 Thus, in Azadi Bachao Andolan case (supra), the Supreme Court found no legal taboo against âtreaty shoppingâ. Treaty shopping and the underlying objective of tax avoidance/mitigation was apparently not equated to a colourable device. That means, if a resident of a third country, in order to take advantage of the tax reliefs and economic benefits arising from the operation of a treaty between other countries through a conduit entity set up by it, the legal transactions entered into by that conduit entity cannot be declared invalid. The motive behind setting up such conduit companies and doing business through them in a country having beneficial tax treaty provisions was held to be not material to judge the legality or validity of the transactions. The approach adopted in McDowellâs case (supra) by one of the Judges that judicial approval should not be accorded to a transaction meant to be a device to avoid the tax irrespective of whether it is prohibited by statute was not endorsed. The principle pithily stated in Duke of West Minster that “every man is entitled if he can to order his affairs so that the tax attaching under the appropriate Acts is less than it otherwise would be” was emphatically approved. However, a colourable device adopted through dishonest methods is one of the areas which could be looked into in judging a legal transaction from the tax angle [vide the dicta of Ranganath Mishra, J. (as he then was) and of the Gujarat High Court in Banyan & Berry]. At the same time, it was made clear in Azadi Bachao case that the word âdeviceâ cannot be used âin any sinister senseâ and the design of tax avoidance by itself is not objectionable if it is within the framework of law and not prohibited by law. However, a transaction which is âshamâ in the sense that “the documents are not bona fide in order to intend to be acted upon but are only used as a cloak to conceal a different transaction” (per Lord Tomlin in Duke of West Minster) would stand on a different footing, as noted by the learned Judges at pp. 761 and 762. It was pointed out that for acts or documents to be a âshamâ, the parties thereto must have a common intention that they are not to create the legal rights and obligations which they give the appearance of creating. Thus, in regard to âcolourable devicesâ and âshamâ arrangements, the scope is still left to ignore such dubious methods subject to the clarifications and caveat entered on the import of the said expressions. It is in the light of the law laid down in Azadi Bachao Andolan and the principles succinctly stated therein, that we have to approach the whole issue in the instant case.
10. The indisputable facts are: the applicant received the funds for the purchase of shares from the parent company, namely, Converging Arrows, USA by way of capital contribution and loans. GDRs were also utilized for the acquisition of some shares. The FIPB unit of Ministry of Finance by its communication dt. 29th Dec., 2004 approved the increase in foreign equity participation in the equity capital of IL&FS Investsmart Ltd. by the applicant (ETM Mauritius). The shares were registered in the name of the applicant. IL&FS has recognized it as the shareholder. The dividends from the shares were being received by the applicant. The applicant represented by its secretary, namely, Abacus Management Solutions Ltd. entered into a share purchase agreement on 16th May, 2008 with HSBC Violet Investments (Mauritius) Ltd. It is clarified by the applicant that a corporate entity can be a secretary of the company under the Mauritius law. The resolution of the applicantâs board of directors was passed on the same day approving the sale of 30,625,629 shares held in IL&FS and Abacus Management Solutions Ltd. was authorized to execute the share purchase agreement and escrow agreement for and on behalf of the applicantâs company. The legal formalities for transfer of shares have been gone through by the applicant. The consideration for the sale of shares was credited to the applicantâs accounts, as borne out from the entries in the audited accounts. On receipt of the sale price, the applicant passed a resolution on 9th Oct., 2008 reducing its capital and paying dividends to its parent. It is thus clear that the applicant-undoubtedly the legal owner of the shares entered into a transaction of sale of shares backed up by boardâs resolution and received the sale price. In this fact situation, ex facie, it is difficult to assume that the capital gain has not arisen in the hands of the applicant, more so when according to the binding pronouncement of the Supreme Court, the motive of tax avoidance is not relevant so long as the act is done within the framework of law, the âtreaty shoppingâ through conduit companies is not against law and the lifting of corporate veil is not permissible to deny the benefits of a tax treaty. None of the grounds on which the Delhi High Court struck down the Circular No. 789 would be of any avail to attribute the capital gains to the holding company situated in USA. By virtue of the Circular No. 789 issued by CBDT (which has been upheld by the Supreme Court), the tax residency certificate issued by the Mauritius authorities is at least a presumptive evidence of the beneficial ownership of the shares and the gains arising therefrom, even if it does not give rise to a conclusive presumption. The indisputable facts noted above together with the normal course of dealings between a subsidiary and its holding company, viewed in the background of the law declared in Azadi Bachao case (supra), do not go to displace the presumption arising from the operation of the circular. The facts that the source of funds for the purchase of shares is traceable to the holding company or that the holding company had played a role in suggesting or negotiating the sale or that the consideration received ultimately goes to the parent company in the form of dividends or the diminution of capital do not lead to a legal inference that the holding company in reality owned the shares and/or the recipient of capital gains arising from transfer of shares is the holding company but not the subsidiary. To take such a view would be clearly contrary to the ground realities of the mutual business and economic relations between a holding and subsidiary company and the inter se legal structure. The fact that the subsidiary has its own corporate personality and is a separate legal entity cannot be overlooked. The fact that the holding company exercises acts of control over its subsidiary does not in the absence of compelling reasons dilute the separate legal identity of the subsidiary. It is unrealistic to expect that a subsidiary should keep off the clutches of the holding company and conduct its business independent of any control and assistance by the parent company. It would have been a different matter if the Supreme Court had disapproved the treaty shopping and the tax avoidance measures. In the present state of law i.e., the treaty provision, the circular of CBDT, the law laid down in Azadi Bachaoo Andolan and the legal incidents of corporate personality, the attempted distinction between legal and beneficial ownership cannot be sustained on any reasonable basis.
11. The Revenueâs counsel, in the course of the arguments, has broadly indicated certain aspects into which an inquiry/verification would be necessary which according to him will have bearing on the question as to who is the beneficial owner of the capital gains. Some of these points also find place in the order of the Director of IT passed under s. 264. In reply thereto, certain clarifications have been furnished by the learned counsel for the applicant in the course of arguments, followed by a written note. Before we may briefly refer to them, we would like to point out that the counsel for the Revenue stated more than once that the question whether the US company was actually exercising acts of ownership over the shares is one relevant point which needs to be looked into. However, it has not been elaborated as to what exactly is meant by exercising acts of ownership and what would be the possible line of inquiry especially in view of the fact that the record discloses the applicant as the owner, the recipient of dividend and the party which entered into the share purchase agreement. Be that as it may, we shall refer to some of these points.
11.1 The first doubt raised is about the execution of the contract that no employee or director of the applicant signed the share purchase agreement dt. 16th May, 2008. It has already been noted that according to the applicant, Abecus Management Solutions Ltd., which is the secretary of the applicant has been authorized to sign and it is competent to act as a secretary. Then it is pointed out by the Revenue that Mr. Todd Mackay who negotiated for the sale of shares signed on behalf of ETFC-the original holding company but not on behalf of the applicant. In response to this, the applicant has stated that Mr. Todd Mackay had negotiated the sale of shares in his capacity as director of the applicant though he is also one of the directors in the foreign holding company. Mr. Donald Layton, Chairman of ETFC signed on behalf of ETFC which figured as âseller guarantorâ in the agreement. Another point raised by the Revenue in its submissions dt. 24th Feb., 2010 that certain directors connected with ETFC were on the board of IL&FS in which the applicant was a shareholder. ETFC was also deputing its senior executives to IL&FS to work there. The applicant states that the parent company never exercised any rights as shareholder in IL&FS. The applicantâs name was entered in the register of shareholders and it was receiving dividends in its bank account and deputing its own representative to attend the shareholder meeting. As regards the appointment of directors and other executives, it was the prerogative of IL&FS and such appointments were made pursuant to the boardâs resolutions. Another point raised in the Revenueâs comments of 24th Feb., 2010 is about the movement of funds between ETFC and the applicant. It is pointed out that not only the funds for investments in shares were sourced from the parent company, even the dividend amount was being remitted to the ETFC as reimbursement of excess fund. As noted earlier, the applicant has admitted that the funds for purchase of shares were received from the parent company by way of capital contributions and loans. The learned counsel for the Revenue has fairly stated that there could be no objection for such sourcing of funds. There is nothing unnatural in the subsidiary company approaching the holding company for additional capital to acquire the shares. It is stated that the nature of the receipt i.e., whether it is capital contribution or loan can be seen from the accounts and the balance sheet. As per the bank account, the funds were sent for closing investments in India. With reference to this, it is clarified that it only shows the purpose for which the funds have been sent and the nature of the receipt i.e., whether it is a capital contribution or loan can be clearly seen from the final accounts and the balance sheet. It is asserted that there is no basis for the allegation that the accounts have been falsified. Regarding the submission of Revenue that on earlier occasions, funds were sent as “return of excess funds and inquiry is therefore needed to find out how the funds have been remitted back to the parent”, the applicant has reiterated that there are boardâs resolutions for declaring the dividends and reduction of share capital by utilizing from the proceeds of the sale of shares (those copies of resolutions have been filed). It is pointed out that the applicant could not have declared the dividends to reduce the share capital, if funds on sale of shares were not received. Upon receiving dividends from IL&FS, there is nothing unusual in a company reducing its liabilities and/or reducing its capital and paying dividends to its parent on receipt of the sale price of shares. The short interval within which the dividends were paid and capital reduction were effected in October, 2008 is not a factor which establishes the beneficial ownership of the shares or the gains resting with the holding company. The applicant maintains that it is free to declare dividends and reduce its capital according to its discretion. The need for passing two resolutions i.e., one for sale of shares and the other for sale of P notes has been explained. With reference to the comment of the Revenue that the inquiries are likely to lead to the conclusion that the investment was made by the parent company directly in the Indian company “as their own investment” and the sale proceeds were also appropriated by them, it is submitted that such inquiry is unwarranted in view of the undeniable facts discernible from the accounts of the applicant and the resolutions of the board. The applicantâs counsel further clarified: the fact that the applicant is the owner of the shares is borne out by record; the source of funds for purchase of shares has been explained with reference to the accounts; and the factum of sale proceeds being received by the applicant is not a matter of dispute. The fact that the sale proceeds were not retained for long by the applicant but remitted to its parent company in USA after taking steps to declare the dividend and reducing the capital are not legally impermissible steps going by the ratio of the decision in Azadi Bachao case (supra). In regard to the exercise of ownership rights allegedly by ETFC, it is pointed out that the directors on the board of IL&FS is appointed by the shareholders and moreover the executive control is in the hands of two directors who are connected with IL&FS Group and not ETFC. It is reiterated that the applicant has always been recognized as the shareholder and it is submitted that its status as shareholder of IL&FS is not in any way affected by the overall control exercised by the holding company.
11.2 The learned counsel for the Revenue has also made some comments on the transitional services agreement dt. 28th May, 2008 entered into between ETFC and IL&FS wherein it is stated that ETFC sold the shares to HSBC Violet. The applicantâs counsel has stated that there is no such clause in the transitional services agreement, a copy of which has been filed in the paper book. Even if such recital was to be found in the draft agreement furnished by IL&FS, the final agreement does not contain such recital. Further, the applicant is not a party to the said agreement dt. 28th May, 2008. It was an agreement between ETFC and IL&FS for the purpose of providing certain services by ETFC to IL&FS on completion of sale of shares.
12. We have adverted to the clarifications furnished by the applicant supported by its accounts and other documents to see whether there is anything to rebut the presumptive evidence of beneficial ownership arising from the tax residency certificate and to see whether there is any compelling reason for not giving effect to the circular of CBDT issued in the context of treaty provisions. We have looked into the facts presented before us in the light of Revenueâs submissions to satisfy ourselves whether there is anything demonstrably clear to show that the capital gain has not arisen in the hands of the applicant or whether any colourable device is apparent. In doing so, the legal position expounded by the Supreme Court in Azadi Bachao case (supra) have been kept in view. The said decision, it may be recalled, has explained what are not objectionable devices in the context of the India- Mauritius treaty and the treaty shopping. On such consideration, this Authority is of the view that the question raised by the applicant shall be answered in the affirmative. On the basis of the facts stated and clarified by the applicant, we uphold the contention of the applicant that by virtue of art. 13.4 of India-Mauritius DTAA, capital gain tax is not liable to be charged in India. We find no justification to accept the Revenueâs contention that the advance ruling should be refused at this stage as further inquiries might unravel some incriminating facts.
We would like to make it clear that it is not within the domain of this Authority to restrain inquiries or eliciting further informations from the US holding company. The scope of inquiry in the light of the law discussed above is limited and could only be within the confines of the legal position clarified by the Supreme Court and this Authority. On the basis of the facts presented by the applicant, many of which are not in dispute and some of which find support from the records, we have recorded the answer to the question posed by the applicant. Though it looks odd that the Indian tax authorities are not in a position to levy the capital gains tax on the transfer of shares in an Indian company, this is an inevitable effect of the peculiar provision in India-Mauritius DTAA, the circular issued by CBDT and the law laid down by Supreme Court in Azadi Bachao case (supra). Whether the policy considerations underlying the crucial treaty provisions and the spirit of the circular issued by the CBDT would still be relevant and expedient in the present day fiscal scenario is a debatable point and it is not for us to express any view in this behalf.
On the facts presented by the applicant and in the light of legal position discussed, the applicant is not liable to pay capital gains tax in India in respect of the transfer of shares held in IL&FS Investsmart Ltd. (Indian company) to HSBC Violet Investment (Mauritius) Ltd. having regard to the provisions of India-Mauritius DTAA. The question is thus answered in the affirmative.
[Citation : 324 ITR 1]

domain: law


text:
I have something in my mind today, so let's talk about it.
Some people tend to not understand what am I saying or explaining to them. Even if I already repeating my words few times! I feel bad. Really bad. When people can't understand my explanation. -_-
I have the tendency of constructing my words in my head in such a way that I thought it would be easier for others to understand it. Thus, I felt real bad when people don't get it.
I know I couldn't make all people understand mine because we are all unique in our own ways.
I tend to be in silence mode when i feel bad nowadays. I will keep my mouth shut. Better than I said something that might hurt others, especially the ones I love.
Thus, if u caught me being silence out of blue, just be there & don't bother me until I get over my bad feeling. It will took me for a while, but all will be good after that insyaaallah.
It is just a part of my new habit.
Hope u don't mind it.
Sorry & thanks.
Fi hifzillah & take care :)

domain: psychology


Syria officially becomes OPCW member
Beginning Monday, Syria officially became a member of the Organisation for the Prohibition of Chemical Weapons (OPCW).
The OPCW’s basic document — the Convention on the Prohibition of the Development, Production, Stockpiling and Use of Chemical Weapons and on their Destruction, also known as the Chemical Weapons Convention (CWC), for short - will now apply to the strife- torn nation.
For several years, the OPCW has been calling on Syrian authorities to join the regime to control chemical weapons but until recently there was no official response.
OPCW Director- General Ahmet Uzumcu confirmed on September 13 this year the receipt of an application from Syria for accession to the Chemical Weapons Convention.
Syria becomes the 190th member-state of the OPCW. The signatory countries account for almost 98 percent of the world’s population.IANS


text:
Nellie – On the fourth day of Christmas, my true love gave to me:
A wagging tail!
Nothing says “I love you” more than a tail wagging furiously at your arrival! Nellie is just waiting to have her own special people to wag a tail for.
Learn more about Nellie, and if you would like to meet this special girl, please complete an application.
Please remember Nellie and the German Shorthaired Pointers and other dogs we are caring for, until we can find their forever homes. Please consider supporting our efforts by making a tax deductible donation to our all volunteer non-profit organization.
Thank you and Happy Holidays from all of us at the California GSP Rescue.

domain: pet


text:
I wrote last year about my fears that theocratic killers would strike against other Muslims and ex Muslims in the UK. That we needed to challenge the theocratic justification that is disseminated to kill them.
This has come too late for Asad Shah. An Amahdi Muslim, the message he put up in his newsagents wishing Christians a Happy Easter summed up their philosophy of love for all, hatred for none. Hours later a Muslim stabbed him to death multiple times, and sat on his chest laughing.
The reports saying it was another Muslim that killed him, misses the nature of the attack. Shah was the wrong kind of Muslim. His killer plunged the blade into someone he regarded as an apostate – someone worthy of death.
To those of you that say, well it is only a theocratic state that is meant to do this under certain conditions, so this is the work of madmen. This misses the Islamic State claims such powers as a caliphate. It misses the persecution that religious minorities suffer under Islamic State constitutions – not least the Ahmadi in Pakistan. It misses the distinction between people who have no rationality, and those with a bloodlust to have their way by calculated means of terror.
Solidarity by saying “I am Ahamdi” is the counter narrative to such justifications. Muslims recognising the Ahmadi as Muslims, challenging the dehumanising of them that occurs. We all have a part to play in this.
Some were quick to call this murder islamophobic. I hope they will be equally quick to condemn the sectarianism and religious fundemantalism behind the killing. To decalre Ahamdi Muslims as part of the Umma, to be one with them as with all humanity. To call them Muslims.
Shah wished all, regardless of their faith or none, love and happiness. He ultimately died for living up to those values. There is no resurrection on the third day for him, but those values can be our salvation this Easter as Europe once again comes to terms with a Jihadist attack in Brussels.
The theocrats want to divide us, to hate, to treat differently. They must not succeed. But unless Government and civil society act and take all forms of extremism seriously, this will not be the last such murder here.
For more on tackling such extremism look at the FATE (Families Against Terrorism and Extremism) initiative.
Article written by John Sargeant on Homo economicus’ Weblog

domain: philosophy


Bhaskar Raju, G and Prabhakar, S and Subba Rao, S (2004) Development of indigenous column flotation technology at NML for the beneficiation of low-grade ores. Metals Materials and Processes, 16 (2-3). pp. 143-156.
NML Madras Centre has designed and developed indigenous automated flotation columns as part of its long term R&D program on the utilization of low-grade ores of India. Both laboratory size and semi-commercial flotation columns were extensively field tested in different mineral processing plants owned by Hindustan Copper Limited, Hindustan Zinc Limited, Kudremukh Iron Ore Company Limited, Sociedade De Fomento Industrial Limited, Bharat Gold Mines Limited, Gujarat Mineral Development Corporation Limited and Indian Rare Earths Limited for the beneficiation of copper, lead and zinc, iron, gold, fluorspar and sillimanite. State-of-the-art equipment was incorporated in both laboratory and semi-commercial flotation columns. Advantages of column flotation technology over conventional flotation machines and salient features of the NML flotation column were discussed in the present paper. Flotation test results obtained both by flotation column and conventional cells were compared. The paper also highlights the potential of column flotation technology in achieving better metallurgical results.
|Uncontrolled Keywords:||Copper ore, iron ore, gold ore, column flotation, separation, sulfide ores, oxide ores, beneficiation|
|Divisions:||NML Chennai > Mineral Processing|
|Deposited By:||Dr. G Bhaskar Raju|
|Deposited On:||26 Sep 2011 14:24|
|Last Modified:||14 Dec 2011 10:52|
Repository Staff Only: item control page


text:
China Green suspends trading after being sued by Convoy as ‘Enigma Network’ fallout continues
Intrigue grows over the goings-on at 50 listed Hong Kong businesses with cross holdings in each other
China Green Holdings, named by stock commentator and activist investor David Webb in the so-called “Enigma Network” of 50 penny stocks trading in Hong Kong, suspended trading on Wednesday after the company was sued by Convoy Global Holdings in a legal action against 28 defendants for causing it substantial financial losses.
Webb issued the report on the network in May, identifying 50 listed businesses that he said had cross holdings in each other, including Convoy, and had approved loans and transactions, which did not make any commercial sense.
Many of the Enigma stocks crashed on June 27 abruptly, by between 20 per cent and 90 per cent. Convoy Global Holdings’ shares have been suspended since December 7.
China Green is named as one of the 28 defendants in a writ of summons filed by Convoy on Tuesday in Hong Kong’s High Court.
“The company (China Green) is currently seeking legal advice on the matter to assess the merits and implications (if any),” China Green said in a statement on Wednesday.
Suspension of its shares on Wednesday is pursuant to the rules and provisions of the stock exchange and the SFC.
Further announcements will be made to update on the progress of the matter “as and when appropriate”, the company added.
“Shareholders of the company and potential investors should accordingly exercise
caution when dealing in the shares of the company.”
Convoy said in the writ on Tuesday it was seeking unspecific damages from 28 defendants, alleging they were involved in gross breaches of fiduciary duties and illegitimate diversions of the company’s funds, causing it “substantial loss and damage”.
One hundred and thirty-six officers from the city’s Securities and Futures Commission searched multiple premises as part of an investigation into the Enigma Network, Bloomberg reported in October.
The defendants named in the writ include former Convoy chairman Quincy Wong Lee-man, former Convoy director Roy Cho Kwai-chee, known to local stockbrokers as “Doctor Cho”, Lerado Financial Group chairman Mark Mak Kwong-yiu, as well as officials from Kaisa Group, China Green and companies owned by listed Junyang Financial Holdings and Hong Kong Education (International) Investment.
Earlier this month, three of Convoy’s executive directors were arrested by Hong Kong’s anti-graft body the Independent Commission Against Corruption, after which Convoy suspended its duties and named them in the writ as defendants.


Samsung Galaxy A7 2017 SM-A720F/DS Combination File BIT 6 (Factory_SW). They help bootloop fix, imei fix. Besides, they also help you to bypass frp.
Samsung A720F Combination File is a raw firmware for engineers and developers to run the device & can fully read and test the equipment of the device.
Download via: Mshare – Google Drive – Google (Backup)
Size: 1.6 GB
Model Name: Samsung Galaxy A7 2017
Security Patch Level: U6


A Cs-137/Ba-137m isotope generator is used to demonstrate the properties of radioactive decay. In this experiment, we investigate and verify the random behavior of radioactive decay and determine the half-life of a radioactive isotope. The half-life of a radioisotope is measured in this experiment. The purpose of this experiment is to determine the half-life of Ba-137m by using several methods and to determine the percent error for each determination. Ba-137m decays by gamma emission (662 keV) with a half-life of 2.6 minutes to the stable Ba-137 element. During elution, Ba-137m is selectively "milked" from the generator, leaving behind the Cs-137 parent. Each generator is supplied with 250 mL of an eluting solution (0.9% NaCl in 0.04M HCl). A Geiger counter interfaced with a computer is used to acquire and record the activity at set time intervals. The half-life of the radioactive isotope Ba-137m is determined by measuring the activity of a sample as it decays. The half-life of Ba-137m, which has been extracted from the radioisotope Cs-137, is detected by using AktivLab. The theoretical half-life of Ba-137m is approximately 2.56 minutes, and the result from the experiment is 2.6 minutes. In summary, a radioisotope generator containing Cs-137 produces Ba-137m, which is extracted in a solution. The Ba-137m has a half-life of about 2.6 minutes as measured during this research.


text:
Syft Synergy Case Study: Why EvergreenHealth Implemented Syft: More Visibility, More Accountability, More Savings
Public hospital needed a supply chain management solution that delivered practical analytics while reducing waste and increasing revenue.
Mounting regulatory burdens, ongoing pressures due to the COVID-19 pandemic, and high rates of staff burnout plagued EvergreenHealth like so many other hospitals. It struggled to allocate adequate resources to supply chain management, which hospital leaders agreed needed a more efficient approach to keep up with clinical and operational responsibilities.
As a public hospital district in Kirkland, Washington, EvergreenHealth has a duty to patients and taxpayers to adhere to five strategic goals, one of which is to continually improve its financial performance to advance service to the community. As the high cost of inefficient workflows and poor supply chain visibility grew, the hospital sought a solution that would reduce supply costs and wasteful spending while improving revenue and staff morale.Download

domain: health


The Conservation of Coastal and Marine Resources Division (CMR) will develop guideline strategies for conservation and long-term sustainable use of coastal and marine resources that encompass societal interests and the integrity of ecosystems.
The primary mandate of CMR would be to guide the use of the living and non living natural resources for diverse, and often conflicting, sectoral activities, so that the continued viability of all aspects of resource usage and ecosystem health can be secured. The important aspect is to Strategy the conservation of coastal and marine resources in ways that promote human wellbeing, for present and future generations. Key issues in the management of coastal resources include the loss of biodiversity and habitats through human-related pressures, and the impacts of biodiversity loss to coastal livelihoods. The CMR Division would provide inputs to the KGP Division to help promote knowledge about coastal and marine ecosystems and their functioning for effective ecosystem-based management. The CMR Division would devise strategies and plans along with the ISE Division for reduction of current and emerging pressures on the coastal and marine resources through adaptive management and co-management activities. The CMR division would undertake research studies on the following key topics:
The CMR will investigate the interactions between natural coastal resources and the coastal communities, with a view to establish the level of sustainable utilization, and thereafter the adoption of conservation ideas in the integrated coastal zone management plans in the country.


text:
Video Poker Machines
Video poker is truly a multiplayer online casino game, based on five-card Pull Poker. In this game, it is possible to either participate in the game yourself or download the game for free and play it in the home. It is in essence played on a computerized interface much like that of a regular slot machine, except that it also features a variety of features including a betting technique, graphics, sound, and a random variety generator. As of the time of this writing, there are a lot more than forty million Internet surfers who partake in movie poker gambling. There are various types of video poker games on the internet, so there is definitely something out there for everybody.
A video poker machine are available in most casinos. They can either be part of the casino’s main casino floor, or a separate one located within a different section of the casino. While there are many independent operators who operate their own virtual slots, nearly all video poker machines are usually linked with the casinos where they are positioned.
The chances of winning in virtually any video poker game are dependent on the strategy that you use while playing. One way to increase the odds of winning is to ensure that you usually do not place your bet if you don’t have a clear idea of the likely odds. To carry out this, you must analyze each of the cards that are in the deck and cautiously consider all the possible outcomes for each and every possible hand. Once you have figured out the odds, it is important that afterward you spread those odds across the various decks of cards so you will be able to maximize your potential winning streak.
There are various types of strategies that competitors can employ when participating in a poker game. A few of these contain bluffing, holdem, Omaha, and five-card stud. You can also find several different types of variations on these basic tactics. You can find Texas Holdem and Omaha games that feature no money, no limit, and the most popular of the being 10-card stud. Each version of the games will have different odds of pay tables, and also different pay ranging from low, medium, and large.
“reduced odds” pays a predetermined sum, and is generally seen as a lower risk type of game. These are an excellent kind of game to play if you are looking to win some cash quickly. When you are playing a low game, you are taking a certain percentage opportunity on the payout of the cards in your side. This is one of the main explanations why casinos offer funds withdrawals from these slots after your win. On the other hand, there is an elevated risk when you are playing with “high chances.”
The “house edge” may be the amount of money that a casino must spend to equal the amount of money the house would obtain if everyone at the modern casino played a single game. This percentage is much higher for video machines than for slots since there is no “loaner” portion for the home to pay off. Instead, it is simply the cost of operation for the gambling machine. Small the house edge, the more income the casino makes by offering more palms for its consumers.
With regard to payout percentages, the two forms of machines have very similar rates. The real difference is based on the frequency with which members win on these machines. Slot machines give their customers smaller sized payouts, and these smaller sized payouts come in the form of fewer bets. The house edge on video poker machines, alternatively, has a much bigger house edge and therefore gives slightly bigger payouts.
Training video Poker Machines Are Better Than Slots: As well as the differences noted above, there are also some differences with regards to how video poker machines work when it comes to performing statistics on the amount of bets taken by customers. In comparison with a traditional casino, video poker machines record the hand histories of members, which means that they are able to determine which players 카지노 게임 사이트 are likely to win. These details is then incorporated in to the machine’s odds, which allow people to know what the likelihood of winning in a specific game is. Although this technologies may not be able to solve every possible problem connected with casino gaming, it has been proven to aid in helping casinos increase their probability of accomplishment.

domain: hobby


text:
Khaidi Karthi movie is a 2019 Tamil action thriller.
Khaidi is a 2019 Telugu film starring Karthi. Lokesh Kanagaraj was called an action thriller and led this project. Narain and Dheena played a central role in the film. The film’s Tamil title is Kaithi. Without the songs, the film made huge box office sales, which is a good move. The effective way of telling a story becomes clear in this film.
Khaidi Karthi movie online streaming now.
The Khaidi karthi movie was released on October 25, 2019 during the Diwali season and was highly praised by critics. The edge of the seated action sequences, powerful performances, committed writing and outstanding background music made the film a great success. Now the film had its world premiere in the OTT app ‘Aha’. The film is now streamed in the Aha app and all premium subscribers can stream the film online.
The film is about Dilli (Karthi), a recently released prisoner who is on the way to meet his daughter for the first time in her life, but eventually gets involved in a cat-and-mouse game between police and criminals.
Director Lokesh is currently working with Vijay on the film master, and after completing this, he could think of the story for the sequel to the film.

domain: artistic


Dec 03, 2016· SILICA: Silica is an abundant mineral on the earth crust, and it is in sand, quartz and any other minerals Some minerals have pure silica but in some, silica are mixed with other elements In silica, the sulfur and oxyden atoms joined by covolent.
Malaysia Quartz Importers Directory - Offering Malaysia's buying leads from buyers, importers, distributors & resellers at Malaysia TradeKey
Kaolin (M) Sdn Bhd is a clay supplier in Malaysia, specializing in manufacturing of silica sand, china clay, mica powder, and sericite in Malaysia
silica quartz malaysia mining Ore plant,Benefication May 13, 2013silica quartz malaysia mining Posted on May 13, 2013 by venscrusher malaysia silica quartz price silica mining process in malaysia Gold Ore View quotes >>mining quartz crystals south africa pwdmumbaicirclein
FUSED QUARTZ WOOL & FELT FUSED QUARTZ WOOL - CLICK TO ENLARGE To order online, simply click on an item number, appearing in the left column of each table, to proceed through our easy ordering system PLEASE NOTE: A minimum order of $50 is required Fused Quartz Wool
dpstar Group is a Malaysia heaters supplier specializing in Maltec-H Infrared Silica Quartz Heaters and heating elements for used in various applications
Pembekal Serbuk Quartz di India Malaysia - We are prominent company engaged in offering superior quality Quartz Powder We provide Quartz powder in the form of snow white, milky white, super semi and semi whiteQuartz powder is used for fibre glass, glass floats, insulator, sanitary ware, refractory, paint, television picture tube, semi-conductors
Silica Sand: Silica sand resources in Malaysia are abundant They comprise largely of natural sand deposits and ex-tin mine tailings The JMG has estimated that the country has some 1484 million tonnes of silica sand reserves located in the states of Johor, Perak, Terengganu, Kelantan, Sabah and Sarawak
May 14, 2019· This video is unavailable Watch Queue Queue Watch Queue Queue
COMPOSITION COMMENT: Silica, Crystalline Quartz (r espirable) California Prop 65: This product does contain an ingredient which is known to the state of California to cause cancer, birth defects, or other reproductive harm SiO2, Silicon Dioxide from long term inhalation See Section 15
Aug 25, 2016· Quartz sand is sand having a very silica sand supplier in johor bahru, BINQ Mining Building Materials in Johor, Hotfrog MALAYSIA, Free online Dry graded Sand,Sand & Silica Sand Graded Sand 8/16 .
Find the 100 lb Silica Sand 5201004095, renowned for quality, uniformity and consistency and ideal for industrial use at The Home Depot
May 13, 2013· Silica sand crusher,silica crushing plant,quartz , in China, and offer Silica sand crushing & screening plant for silica sand mining, processing in Malaysia , required silica in malaysia On the demand side,exporters and strategic planners focusing on natural sands excluding silica and quartz sands in Malaysia face ,
Malaysia Silica Sand, Malaysia Silica Sand Suppliers and Manufacturers Directory - Source a Large Selection of Silica Sand Products at sand casting equipment ,river sand ,sea sand from Malaysia ,
InfodriveIndia provides latest Quartz Export from India to Malaysia and statistics from actual shipment data from Indian Customs InfodriveIndia covers Quartz Export from India to Malaysia shipments in 180+ ports in India and export data is available with a backlog of just 3 days
Production of dry silica Grade sand sand, 8/16 silica sand , 16/30 silica sand , 30/60silica sand, 60/100 silica sand and other saizs silica sand Address:Malaysia Product/Service:grade silica sand,,grade silica sand, Taglink Group We are supplier of hig quality grade silica sand from Malaysia and able to sell to any part of the world
Terengganu Silica deposit is located in Setiu, in the state of Terengganu, Malaysia The largest silica resource in Asia of an area of more than 1000 hectares of lease land with proven reserve of more than 60 million ton of high purity grade silica, having strategically located resource and plant facilities in center of Asia and closer to customers
silica powder making plant malaysia ferramentafriulanait Silica Powder Supplier, Natural Quartz Powder, Silica, Snow White Quartz Silica Powder Quartz is the most abundant and most common mineral on the Earth It is found in almost every geological environment and also it is at Sericite Supplier Malaysia , Kaolin China Clay , Mica Powder
Fused quartz is developed by melting crystalline silica in sand or stone form Often used in the same applications as fused silica, it has a significantly lower OH content Fused quartz possesses a high degree of purity, high chemical resistance, good thermal ,
Manufacturer of Filter Sands - Quartz Silica Sand, Water Filter Sand, Silica Sand and River Sand offered by Mahavir Chemical Industries, Delhi Manufacturer of Filter Sands - Quartz Silica Sand, Water Filter Sand, Silica Sand and River Sand offered by Mahavir Chemical Industries, Delhi
View detailed Export data, price, monthly trends, major exporting countries, major ports of quartz powder silica Export Data and Price of quartz powder silica | Zauba Skip to main content
Malaysia feldspar Suppliers & Manufacturers , include Pratham Impex Pte Ltd , SRI BATAM SDN BHD , Xinoma Commodity Trading House , CERAMIC MATERIAL SUPPLY SDN BHD .
Syarikat Sebangun Sdn Bhd Being blessed with high quality of silica sand deposit, Sebangun's silica sand is now reputed to be one of the most sought-after raw materials by glass producers for the last three decades in the region Sebangun's sand is also used for the production of glass products, sodium silicate, resin coated sand and ceramics tiles, the exporting countries by Syarikat .
Tosoh manufactures fused silica glass (aka fused quartz) and optical silica glass (aka synthetic fused silica) materials for use in the semiconductor and optical industri
Silica Fume Malaysia Wholesale, Fume Suppliers – Alibaba Alibaba offers 16 silica fume malaysia products About 87% of these are silica, 6% are oxide A wide variety of silica fume malaysia options are available to you, such as silica powder, silica quartz Silica Fume, Malaysia Silica Fume Suppliers Directory on ,
Our mine is located in Perak, Malaysia We estimate our reserves to be 2 million tonn wish partner some strong multi-nationals supply high grade silica sand will fully operational by the first quarter of next year with an initial output 5,000 MT per monthI .
Silica Sand is quartz that over time, through the work of water and wind, has been broken down into tiny granul Commercial Silica Sand is widely used as a proppant by companies involved in oil and natural gas recovery in conventional and unconventional resource plays The resource is also used in industrial processing to make everyday
Best gloss and longevity out of any coating I've used The gloss is unreal I don't use anything else now and I have used and tried about every silica based coating on the market and by far the best one there is Great products, amazing people and an amazing company Don't second guess, just make the plunge and go with IGL Coatings
Fused Silica Lump, Quartz Tube, Barite Powder Type: Silica Powder Model Number: fused silica sand Application: Refractory Our company is a major manufacturer of silica (quartz) products such as high purity silica sand, sil Our company is a major manufacturer of silica (quartz) products such as high purity silica sand, silica powder, micro-silica powder
Malaysia Quartz | quartz surfaces offer strength, heat and scratch resistance, and the timeless beauty of natural quartz to kitchen counter Malaysia Quartz Stone Surface Malaysia kitchen Cabinet Quartz Tops


Speciality Metals (ASX: SEI) has bought the Mt Carbine Quarry including all plant and equipment, along with mining leases ML 4867 and ML 4919.
The Mt Carbine Quarry acquisition lands SEI a revenue stream as it looks to expand its exploration portfolio and become the pre-eminent Australian tungsten producer from the historic Mt Carbine tungsten mine in far North Queensland.
The Mt Carbine tungsten mine consists of the Iron Duke and Petersens Lode exploration permits.
SEI, formerly Carbine Tungsten Limited (ASX: CNQ) has several projects it is working on, including lithium and other mineral resources such as potassium, iodine and boron contained in subsurface brines within its Chilean exploration concessions; as well as gold exploration licences (Panama Hat and Crow Mt) in New South Wales, Australia.
Executive chairman Russell Krause said, "Negotiations are well advanced with several interested offtake and debt funders in an attempt to minimise the transaction's dilutionary impact upon existing shareholders. The company is also continuing to progress and refine its plans for recommissioning the tailings retreatment plant along with its intention to commence early production via the use of ore-sorting technology and high-grading the ore contained within the low grade stockpile. The relatively firm European tungsten APT price (Ammonium Paratungstate) has also greatly assisted in the negotiation process having restored a degree of confidence in the tungsten market".


text:
|Nearby airports||5 found|
The nearest airport to Canterbury Christ Church University is London Heathrow (LHR). You can take a train from London Heathrow (LHR) to Canterbury Christ Church University via Farringdon Without, Farringdon, London St Pancras Intl, and Canterbury West in around 2h 34m.
Want to know about travelling to Canterbury Christ Church University? We have put together a list of the most frequently asked questions from our users such as: What is the cheapest mode of transport?, What is the quickest option?, How much do tickets usually cost? and many more.
The nearest airport to Canterbury Christ Church University is Southend (SEN) Airport which is 26.2 miles away. Other nearby airports include London Gatwick (LGW) (55.1 miles), London Stansted (STN) (55.5 miles), London Heathrow (LHR) (68.2 miles) and London Luton (LTN) (75.8 miles).More information
It takes 2h 34m to get from St Peters to London Heathrow (LHR) Airport.More information
We recommend flying to London Heathrow (LHR) Airport, which is 81.4 miles away from St Peters. The train from London Heathrow (LHR) to St Peters takes 2h 34m.More information
There are 1747+ hotels available in Canterbury Christ Church University. Prices start at $56 USD per night.More details
Compare your options: plane, train, bus, car, ferry, bike share, driving and walking directions all in one search.Learn more about our apps

domain: geography


text:
“You want everyone to have a sexy night," the brunette beauty said last night, "and I like writing sexy music because Miami is the sexiest place on Earth."
“I love working in the studio or doing stills, or designing or inspiring," Harris said. "I’m more of a muse figure.“
One source of constant inspiration for Harris' upbeat party pop is Miami Beach, she said.
“It’s a melting pot," Harris said. "There’s always a pulse here."

domain: celebrity


Extending the Scope of Labour Market Integration of Immigrants
Institute of Baltic Studies, in cooperation with partner organisations from six EU countries, is carrying out a project (MIGRASCOPE) aiming to increase access to work and reduce barriers for migrants. This will be achieved through implementing new good integration practices at the workplace by employers and increasing knowledge and better expectation management among migrants. The project also aims to identify and empower successful migrant entrepreneurs who would act as role models and to facilitate the access to work and reduce barriers by developing innovative and interactive e-tools.
The activities for the MIGRASCOPE project include work-shadowing, creating a best practice toolbox, development of two e-services together with mobile app, identification of expectations among migrants and organisation of interactive workshops for migrants. Altogether, around 400 immigrants are expected to participate in the interactive workshops and more than 100 employees to take part in the work-shadowing activities. The project also involves various social partners (including civil society organisations) and state and local government authorities.
MIGRASCOPE project expected results include:
- increased access to work and reduced barriers to migrants;
- new good integration practices implemented at the work place by employers;
- increased knowledge and better expectation management among migrants;
- increased awareness about migrant workers among employers;
- interactive, user-friendly and innovative e-services implemented to facilitate access to work;
- enlarged pool of policy know-how on access to work and integration at the work place.
The project is funded by the European Union from the Asylum, Migration and Integration Fund (AMIF) and it lasts until October 2018.


NIOSHTIC-2 Publications Search
Time-factors in exposure effects among uranium workers.
Richardson DB; Wing S
NIOSH 2006 Feb; :1-36
The Oak Ridge, Tennessee Y-12 plant has operated as a nuclear materials fabrication plant since the 1940s. Given the work environment, and prior findings that lung cancer mortality was elevated among white male Y-12 workers relative to US white males, we investigated whether lung cancer mortality was associated with occupational radiation exposures. We identified a cohort of 3864 workers hired between 1947 and 1974 who had been monitored for internal radiation exposure. Vital status was ascertained through 1990. Over the study period 111 lung cancer deaths were observed. Cumulative external radiation dose under a 5-year lag assumption was positively associated with lung cancer mortality (0.54% increase in lung cancer mortality per 10 mSv, se=0.16, likelihood ratio test [LRT]=5.84, 1 degree of freedom [df]); cumulative internal radiation dose exhibited a highly-imprecise negative association with lung cancer mortality. The positive association between external radiation dose and lung cancer mortality was primarily due to exposure occurring in the period 5-14 years after exposure (0.97% increase in lung cancer mortality rate per 10 mSv, se=0.28, LRT=6.35, 1 df). The association between external radiation dose and lung cancer mortality was negative for exposures occurring at ages <35 years and positive for exposures occurring at ages 35-50 years and 50+ years. Conclusions about the relationship between occupational radiation exposures and lung cancer in this population, however, are constrained by the uncertainties in external and internal radiation dose estimates, the lack of information about exposures to other lung carcinogens, and the limited statistical power of the study.
Ionizing-radiation; Lung-cancer; Respiratory-system-disorders; Pulmonary-cancer; Pulmonary-system-disorders; Nuclear-radiation; Radiation; Radiation-exposure; Epidemiology; Statistical-analysis; Mortality-data; Mortality-rates; Mortality-surveys
David B. Richardson, Department of Epidemiology, School of Public Health, University of North Carolina at Chapel Hill, Chapel Hill, NC 27599-7435
Final Grant Report
NTIS Accession No.
National Institute for Occupational Safety and Health
University of North Carolina - Chapel Hill
Page last reviewed: July 23, 2021
Content source: National Institute for Occupational Safety and Health Education and Information Division


text:
Adding Vectors that are not perpendicular. Holt Physics Chapter 3 Section 2 (continued). Non-perpendicular vectors. Because vectors do not always form right triangles, you cannot automatically apply the Pythagorean theorem and tangent function to the original vectors. Vector 2.
346 views • 11 slides
View Resolve vector 2 PowerPoint (PPT) presentations online in SlideServe. SlideServe has a very huge collection of Resolve vector 2 PowerPoint presentations. You can view or download Resolve vector 2 presentations for your school assignment or business presentation. Browse for the presentations on every topic that you want.

domain: mathematics


CALGARY – Oilsands plants will net price premiums of up to $20 a barrel by extending exports to the Gulf of Mexico coast, TransCanada Corp. president Harold Kvisle predicted Thursday.
Thirsty Texas and Louisiana refineries routinely pay more than crowded markets closer to the Alberta bitumen belt.
TransCanada is poised to build new southbound links to the Gulf facilities.
Oilsands supplies are sought after in the region as secure and reliable replacements for unpredictable imports from declining production sources in Venezuela and Mexico, he said.
About $5.2 billion in construction will start this spring on the first and longest leg in a planned new oil route from the Hardisty pipeline hub southeast of
Edmonton to the U.S. gulf coast, Kvisle told an industry conference held by Insight Information.
Read the entire article here:


on 26 August 2020
They're all very evenly matched, so it's hard to pick one. I'd probably have to rewatch them again and see how I feel now, some 10 years since I last watched them, but I was always very fond of the Ents and the Wizards (the two key ones being played by the absolutely perfect choice of actors in Ian McKellen and the late Christopher Lee) in the novels and the films, so I voted for Two Towers.
That said, Return of the King includes my favourite scene in the entire series - the Mouth of Sauron.
The Hobbit movies have come up, so I'll add my view of those: I don't think they were bad; they're definitely watchable. But they're not even close to being on the same level as The Lord of the Rings trilogy (LotR films I all gave 9 to, The Hobbit films are all 7s). They're much more childish and child-like, with sequences that stretch credibility (the escape from Goblin Town). The characters aren't as interesting, likeable, or as well developed either, despite the films being stretched to like 9 hours. The content they're based on is much weaker, so I'm not sure I place much or even any blame on Peter Jackson. It'd be interesting if they were remade with a whole new director and production team and if that made any difference. I'm not sure it would, but who knows.
The Lord of the Rings is epic filmmaking at its finest
The Hobbit is light-hearted popcorn fare.
Both have their values and I'm fond of both, but they're very different in scope, style, and goal. That said, I agree with pretty much everybody that The Hobbit could have and should have been one movie. I liked it, and I was completely okay with the added content, but I definitely feel that being edited down to one three-hour movie would have been plenty. hell, two and a half hours would be enough for The Hobbit. Regardless, I still quite enjoyed the movies, all six of them. I just acknowledge that each trilogy was made with vastly different tones and goals in mind. I think that's what people need to understand; the hobbit was never going to be an epic, Lord of the Rings style masterwork, it was always going to be light and fluffy, just like its source material.
My Console Library:
PS4, PS3, PS2, PS1, WiiU, Wii, GCN, N64 SNES, XBO, 360
3DS, DS, GBA, Vita, PSP, Android
Top 6 this generation:
Bloodborne, Sekiro: Shadows Die Twice, God of War, The Legend of Zelda: Breath of the Wild, Dark Souls III, Red Dead Redemption II, Rock Band 4


Get it by Christmas! Order by December 16, 2016 @ 3pm CT
High-Quality ABS Plastic
What's in the Box
(1) Series 58 Battery Cover
Series 58 Battery Cover
Whether you're taking your car to a car show, or you simply like the refreshing look of a clean engine bay, this 1987-2004 Mustang battery cover is exactly what you need to dress up your engine bay. This high-quality Mustang battery cover is constructed from ABS plastic for ultimate durability and great looks! With a black textured finish, this battery cover will look like it came from the factory. Easy installation makes this a must have for your Mustang's engine bay.
This will fit 1987-2004 factory and aftermarket batteries that are Series 58 ONLY.
Check out our YouTube channel for even more tech tips, installation videos, how-tos, and more. The best place to go for anything Mustang related!
Published on 2015-09-24 These battery covers are manufactured out of high-quality ABS plastic, will feature a black textured finish, and the main reason why you need one of these, is that it hides that awful looking battery!
They are available for all 87-14 Mustangs with the appropriate 58, 89 or 96 series battery. Double check the top of your battery for a part number or call the manufacturer to ensure the right battery is in your Mustang.
I have been restoring my car for a long time. The engine is a 331 stroker afr 185 heads, trick flow r series intake, 1 3/4 in long tubes with flow master dumps. Sounds awesome and love it every ride. ...