Decision No
 

PENALTY TAX -
 

failure to keep proper records and file correct tax returns - onus of proof - s 82A of the Inland Revenue Ordinance
 

failure to file profits tax return within specified time limit - reasonable excuse and quantum of penalty - s 82A of the Inland Revenue Ordinance
 

quantum of penalty - failure to file profits tax return within time stipulated - s 82A of the Inland Revenue Ordinance
 

professional practitioner - appeal lodged out of time - s 82B(1)
 

interest income - whether interest accrues over a period of time or at the moment when it is due for payment
 

holding company - sale of shares in subsidiaries - whether profit taxable
 

assets betterment statement - onus of proof
 

company incorporated in Hong Kong not represented at hearing - whether Board has power to hear appeal
 

purchase of uncompleted flat sold at a profit - purchasers both experienced in real estate dealing - whether sale of flat a trading transaction
 

sale of property - whether property acquired for residential purposes or for trading purposes
 

assets betterment statement - onus of proof - whether expenses deductible
 

source of income - taxpayer overseas - procedure to be followed - whether source in Hong Kong