Decision No
 

PENALTY TAX -
 

late filing of profits tax return - more tax had been paid - quantum of penalty - s 82A of Inland Revenue Ordinance
 

filing incorrect profits tax returns - additional tax - whether excessive - s 82A of Inland Revenue Ordinance
 

filing incorrect salaries tax return - s 82A of Inland Revenue Ordinance
 

omission from tax return of one of two sources of salary - omission claimed to be simple mistake due to change of job - whether penalty tax of 25% excessive in the circumstances - Inland Revenue Ordinance ss 82A and 82B
 

late filing of profits tax return - quantum of penalty tax - s 82A of Inland Revenue Ordinance
 

submitting incorrect salaries tax returns - additional tax - s 82A of Inland Revenue Ordinance
 

late lodgment of profits tax return - delay in lodgment claimed to be due to difficuties in finalizing accounts - whether penalty tax of 9.17% excessive in the circumstances - Inland Revenue Ordinance ss 82A and 82B
 

purchase of land, development and sale of units in second phase of an industrial building - proceeds of sale used to repay costs of financing - whether trade or disposal of a capital asset - whether change of intention during construction - Inland Revenue Ordinance s 14
 

garment trading - taxpayer as a link between manufacturers and companies outside Hong Kong - source of profit - s 14 of Inland Revenue Ordinance
 

garment manufacturing and trading company - exchange losses - whether deductible or not
 

royalties - trade mark - used in Hong Kong - s 15(1)(b) - s 70A of the Inland Revenue Ordinance
 

s 8(1) - employment by Hong Kong company - income arising in or derived from Hong Kong; and s 8(1A)(1B) - employment by overseas company - apportionment of time in and out of Hong Kong - calculation of part days and non-working days