Decision No
 

PENALTY TAX -
 

repeated delay in submitting tax returns — whether there is reasonable excuse for the delay — assessment of the additional tax — whether the assessment is excessive
 

D63/04 (Word file)

whether additional tax assessment under s 82A of the Inland Revenue Ordinance (‘IRO’) excessive — whether appellant co-operative with Revenue in the investigation of his tax affairs — whether case distinguishable from D103/01
 

D65/04 (Word file)

paintings hang on the walls of barristers’ chambers — whether ‘plant’ for the purposes of producing profits in the practice at the Bar — s 39B of the Inland Revenue Ordinance (‘IRO’)
 

D52/04 (Word file)

source of profits — goods manufactured outside Hong Kong by a joint venture company
 

D56/04 (Word file)

onus wholly on the appellant to show the assessment excessive or incorrect on appeal — s 68(4) of the Inland Revenue Ordinance (‘IRO’
 

D57/04 (Word file)

PROPERTY TAX -
 

late in submitting the notice of appeal — application for an extension of the time limit of appeal - s 66 of the Inland Revenue Ordinance (‘IRO’) — personal work pressure and busy working and family situation cannot be reasonable cause for the time extension of appeal — the belief that time extension would be allowed is incorrect. [Decision in Chinese]
 

D54/04 (Word file)

whether the sums are cash allowance chargeable to tax — whether the sums are refunds of rent — ss 9(1)(a), 9(1A)(a) and 68(4) of the Inland Revenue Ordinance (‘IRO’) — the contractual agreement would shed light on whether the sum in question was consideration paid for use of a property
 

D53/04 (Word file)

secondment — whether a new contract of employment exists — whether all services rendered outside Hong Kong — ss 8(1A)(b),(c) of the Inland Revenue Ordinance (‘IRO’)
 

D60/04 (Word file)

s 9 of the Inland Revenue Ordinance (‘IRO’) — whether losses arising from the sale of share warrants properly deductible from assessable income — whether s 9(5) entitled the appellant to make such a deduction — whether consideration paid for share warrants properly subject to salaries tax
 

D68/04 (Word file)

housing allowance — whether bona fide landlord and tenancy relationship
 

D69/04 (Word file)