Decision No
 

PENALTY TAX -
 

making incorrect salaries tax return by omitting part of income - whether assessable to penalty tax - whether assessment of 25% excessive
 

delay in filing profits tax returns - whether penalty tax assessments excessive
 

s 68(2D) - hearing in the taxpayer's absence - exercise of discretion by the Board - s 82A - amount of penalty decided on its own merits - 10% starting point - gross negligence - substantial omission
 

profit derived from sale of property - whether assessable to tax
 

sum payable as per contract on termination of employment - amount of sum payable based on compromise between the parties - whether assessable to salaries tax
 

whether housing assistance paid to taxpayer by employer was rental refund or cash allowance - taxpayer residing with his parents - 'lease agreements' entered into by taxpayer - agreements not submitted for stamp duty - whether landlord and tenant relationship existed - whether control exercised by employer over payment of housing assistance - Inland Revenue Ordinance ss 8(1) and 9(1)(b), (1)(c), (1A) and (2); Stamp Duty Ordinance (Chapter 117) s 15(1) and First Schedule, head 1(2)
 

s 8(1A)(b)(ii) - a continuous contract of employment or two separate contracts in the year of assessment