Decision No
 

PENALTY TAX -
 

repeated failure to file tax return - family circumstances - ill health of children - s 82A of the Inland Revenue Ordinance, Chapter 112
 

failure to submit a profits tax return within the stipulated period - unintentional delay - penalty in the rate of 10% of the tax undercharged under s 82A of the Inland Revenue Ordinance (the 'IRO')
 

sale of property - whether for long term investment or used as a trading asset - ss 2, 14(1) and 68(4) of the Inland Revenue Ordinance, Chapter 112
 

sale of property - change of the intention of purchase - whether audited accounts truly reflect the state of affairs of the company concerned - urgency in the preparation of the account - lack of contemporaneous document to support
 

acquisition and sale of property - intention of purchaser at time of acquisition - burden of proof on taxpayer purchaser - whether tax chargeable on the profits of sale
 

consultancy fee - recipient company almost wholly owned by the taxpayer - whether deductible expense - artificial arrangements - s 61 of the Inland Revenue Ordinance (the 'IRO')
 

whether profits from the sale of a property assessable to profits tax - whether 'prevented' from giving the requisite notice of appeal - ss 66 and 68(4) of the Inland Revenue Ordinance (the 'IRO')
 

sale of property - whether profits derived from the sale of the property assessable to profits tax - intention at the time of acquisition - whether the taxpayer is necessary to show a pressing need to purchase or to sell - s 14 of the Inland Revenue Ordinance
 

asset betterment statement - burden on taxpayer to show it incorrect or excessive
 

real property - whether the gains arising from the disposal of a property was liable for profits tax - ss 2, 14 and 68(4) of the Inland Revenue Ordinance
 

real property - whether the gains arising from the disposal of a property was liable for profits tax
 

acquisition of property - intention at time of purchase - burden of proof on purchaser to establish that property purchased for long term investment - whether tax chargeable upon revaluation of property - ss 2(1), 14 and 68(4) of the Inland Revenue Ordinance
 

deduction - expenses for self education - 'paid in the year of assessment' - ss 2(1), 12(1)(a), 12(1)(e) and 12(6)(d)(i) (A) to (F) of the Inland Revenue Ordinance (the 'IRO'), Chapter 112
 

severance payment - whether taxable because of immediate re-engagement
 

deductions claimed in respect of certain payments - notice of appeal not filed in time - whether time for filing ought to be extended - discretion of the Board - s 66(1A) of the Inland Revenue Ordinance
 

allowable deductions - dependent parent allowance - whether the dependent parent was ordinarily residing in Hong Kong in the relevant year of assessment - whether taxpayer entitled to claim deductions - s 30 of the Inland Revenue Ordinance (the 'IRO')