taxworry.com: Miscellaneous

Showing posts with label Miscellaneous. Show all posts

Showing posts with label Miscellaneous. Show all posts

Thursday, February 07, 2008

When Can A Person Be Said To Be Dependent On Others?

1. An employee wants to claim rebate under Section 80D for his father /mother who is getting pension. Is it allowed?

2. Under what circumstances the children of an employee are dependent (regarding age etc.)

Padma Hosamani

It is important that law makers have prefixed words "parents or children " with dependant in section 80D. It means that payments for mediclaim for parents or children are not eligible for deduction u/s 80D if they are not "dependant" on the individual. However, there is no definition of "dependant " under the I T Act.

In absence of definition, we should refer the natural meaning of dependant. The term “dependent” has been defined as “[o]ne who relies on another for support; one not able to exist or sustain oneself without the power or aid of someone else.” Black's Law Dictionary 470 (8^th Ed. 2004)

In my opinion if the person (parent or child) has his /her own source of income to the extent that he /she can support him/self of all daily necessities , he /she is not dependent? In that case , 80D is not claimable.

While pension can be independent source of income, still if the amount of pension is not very big that a person having retired age can fulfil all his normal and medical expense, the income can not be said to be to such an extent that the parent can be called as independent . So even in that case , the son /daughter has to spend money for upkeep of his/her parents.I believe the deduction u/s 80DD is claimable in that case.

Wednesday, February 06, 2008

How To Save Tax In Case Of Deep Discount Bond?

I hold ten Deep Discount bonds issued in 1996 by ICICI Bank with face value( redemption value) of Rs. 16000 each.The issue price was Rs. 4000 each. I have not declared interest accrued annually in my tax return. The Bonds shall be due for redemption in October 2008. Please inform the best way to save income tax. Sharad, Delhi

Remember , in case Deep discount bond, two kinds of income may generate in two different conditions;

If the bond matures, the redemption price minus the issue price will be charged as interest income.
If you sale before maturity, the difference between Sale price and issue price will be charged to capital gains.No indexation is allowed as section 48 of the I T Act does not permit indexation incase of bonds and debenture.

Since the tax rate in case of long term capital gains is 20 % , selling before maturity is better tax planning if your total income happens to be in 30 % rate bracket .

In your case , the total interest chargeable to tax comes to Rs. 1,20,000 (RS 12000 x 10). I presume, combined with other income, the tax rate applicable in your case must be 30 % .

Therefore, it is certainly beneficial to sale the bond before the maturity, so that difference between the sale price and issue price is charged to capital gains and income from other sources. That way not only tax rate will be 20 % but if you want exemption you can invest insale price in residetaila hoiuse pruchase for sectuon 54 F benefit or can purchase specified bonds as stated u/s 54 E .

Non Declaration of Interest Every Year

Since you had subscribed to the bond in 1996, Circular No 2 of 2002 dated 15.2.2002 is not applicable in your case . This circular made it compulsory for subscriber to Deep Discount Bond , to declare the accrued interest every year. The relevant portion of the circular is given below:

3. The matter has now been examined in consultation with the Reserve Bank of India and the Ministry of Law. The practice followed in several countries outside India has also been examined. With a view to remove the anomalies in the existing system of taxation of income from Deep Discount Bonds, and to formulate a system which is more in line with international practice, the Board have decided that such income may hereafter be treated as follows.

General treatment

4. Every person holding a Deep Discount Bond will make a market valuation of the bond as on the 31st March of each Financial Year (hereafter referred to as the valuation date) and mark such bond to such market value in accordance with the guidelines issued by the Reserve Bank of India for valuation of investments. For this purpose, market values of different instruments declared by the Reserve Bank of India or by the Primary Dealers Association of India jointly with the Fixed Income Money Market and Derivatives Association of India may be referred to.

4.1 The difference between the market valuations as on two successive valuation dates will represent the accretion to the value of the bond during the relevant financial year and will be taxable as interest income (where the bonds are held as investments) or business income (where the bonds are held as trading assets).

4.2 In a case where the bond is acquired during the year by an intermediate purchaser (a person who has acquired the bond by purchase during the term of the bond and not as original subscription) the difference between the market value as on the valuation date and the cost for which he acquired the bond, will be taxed as interest income or business income, as the case may be, and no capital gains will arise as there would be no transfer of the bond on the valuation date.

Transfer before maturity

5. Where the bond is transferred at any time before the maturity date, the difference between the sale price and the cost of the bond will be taxable as capital gains in the hands of an investor or as business income in the hands of a trader. For computing such gains, the cost of the bond will be taken to be the aggregate of the cost for which the bond was acquired by the transferor and the income, if any, already offered to tax by such transferor (in accordance with para 4 above) upto the date of transfer.

5.1 Since the income chargeable in this case is only the accretion to the value of the bond over a specific period, for the purposes of computing capital gains, the period of holding in such cases will be reckoned from the date of purchase/subscription, or the last valuation date in respect of which the transferor has offered income to tax, whichever is later. Since such period would always be less than one year, the capital gains will be chargeable to tax as short-term capital gains.

Redemption

6. Where the bond is redeemed by the original subscriber, the difference between the redemption price and the value as on the last valuation date immediately preceding the maturity date will be taxed as interest income in the case of investors, or business income in the case of traders.

6.1 Where the bond is redeemed by an intermediate purchaser, the difference between the redemption price and the cost of the bond to such purchaser will be taxable as interest or business income, as the case may be. For this purpose, again, the cost of the bond will mean the aggregate of the cost at which the bonds were acquired and the income arising from the bond which has already been offered to tax by the person redeeming the bond.

.................

Tax deduction at source

8. The difference between the bid price of a deep discount bond and its redemption price, which is actually paid at the time of maturity, will continue to be subject to tax deduction at source under section 193 of the Income-tax Act. Under the existing provisions of that section, no tax is deductible at source on interest payable on Government securities. Further, the Central Government is empowered to specify any such bonds issued by an institution, authority, public sector company or co-operative society by way of notification, exempting them from the requirement of tax deduction at source.

Circular : No. 2/2002, dated 15-2-2002.

However , Clarifications were issued vide press release dated 20/3/2002 that the circular no 2 of 15/2/2002 is not applicable for bonds issued before 15/2/2002.

It is also an established principle that a circular issued by CBDT cannot have a retrospective tax effect. The present circular on deep discount bonds, therefore, specifies the tax treatment in respect of bonds which are issued after the issue of the circular, and does not seek to impose the modified treatment on existing bond-holders. Further, non-corporate persons who invest small amounts in new issues (face value upto Rs.1 lakh) can still opt for the old system.

Therefore, even if you did not declare the interest every year, it is not a problem.

Thursday, July 19, 2007

Why Are We Required To Affix Revenue Stamp of Rs One on Cash Receipt?

Is it necessary to paste a 1/- Re revenue stamp on the rent receipt?2. Do I need to furnish every month's rent receipt to claim the HRA? Or can I just attach one month's rent receipt for the same.same.3pankajkalra@................in

The Rent receipt gets a legal sanctity when it fulfills the provision of law passed to regulate such transactions. As per Indian Stamp Act , certain receipts should have to be affixed with stamp.

Section 2(2 3) of the Indian Stamp Act 1899 makes it mandatory for affixing of stamp on any receipt as defined therein above Rs 5000 .[Previously it was Rs 500]

2(23) "Receipt" includes any note, memorandum or writing-
(a) whereby any money, or any bill of exchange, cheque or promissory note is acknowledged to have been received, or
(b) whereby any other movable property is acknowledged to have been received in satisfaction of a debt, or
(c) whereby any debt or demand, or any part of a debt or demand, is acknowledged to have been satisfied or discharged, or
(d) which signifies or imports any such acknowledgment;
and whether the same is or is not signed with the name of any person "

Therefore, affixing stamp does not depend on month or year , but every time a receipt is given. If every month receipt above Rs 5000 is given, stamp has to be affixed there. If only one receipt at the end of year is given , one stamp is required. The basic requirement under the law is RECEIPT.

Wednesday, January 24, 2007

Enjoy Latest News on Tax!

Dear readers

On the right side bar , I have now added a window wherein latest news on Indian tax matters shall be displayed. This will fulfill my dream of giving readers better value for money ! Just joking .No body pays money to read and get the advice on this blog. Readers' comment on the new "addition "and any other topic they want is eagerly awaited.

do write in at taxquery @gmail.com

Monday, January 15, 2007

10 Questions He Asked to Help His Friend. Good!

A friend Mr Selvaraj sundaram_selvaraj@.in has not filed IT in his life even though there has been Form 16's with tax deductions. He has asked following questions to help his friend. Answers are given below the question itself

(1) How to file the IT returns for the last few years?

Answer 1: Even if one forgets to file the return during one year from the end of assessment year for any Genuine reason , still return can be filed . The commissioner of income tax who has the jurisdiction over your friend can be prayed u/s 119[2][b] of the I T Act for condoning the delay in filing the return.Your friend can file return even for six back years.
(2) Will there be any monetary penalty for every year of non-filing?

Answer 2: Yes, there can be , if commissoner thinks so . But if there is genuine reason , he may condone it . Frankly, few CIT will do that.

(3) If for a particular year, if some tax is due, what is additional penalty.

Answer 3: The rate of penalty is minimum 100% to 300% of tax sought to be evaded. But remember, you will also be imposed with interest u/s 234B and 234C of the I T Act. However, even these interest can be waived by CIT or CCIT through a separate application.

(4) If and in case, there is refund possible, will it be given?

Answer 4.Yes , Refunds can be given. In fact most of the application u/s 119[2][b] of the I T Act are for refunds claim.
(5) There could be some capital gains/losses from investments in mutual funds, stocks, margin trade and derivatives. What are the different rates of taxes for short and long terms? Is the thumb rule same for the last decade?

Answer 5 No , long term gains is tax free from Asst Yr 2005-06 and 10% on short term. Before that Long term was 20% or 10 % and short term was normal tax rate .
(6) What is the minimum income for a person, to file a return for a given fin year over the decade? what are the std deductions and exemptions?

Answer 6: From Fy 1995-96 to 1997-98 Rs 40000 ;

From FY 1998-99 to 2004-05 Rs 50000;

From FY 2005-6 Rs 100000.

(7) From July 2005 STT is deducted for mutual fund redemptions, how is that to be used in calculating capital gains?

Answer 7 : There is no deduction or rebate or allowance of STT in case of capital gains even if STT is deducted on mutual funds. Section 88E is there for relief on account of STT , but only if the shares or equity or mutual fund income were taxable under the head "Profit from Business ".

(8) His investments have been from the joint account with his wife. So can he only declare only 50% of gains? (while the other 50% may bot be greater than the minimum amount required for filing a return for his wife.

No and Yes. If he was the only earning member and he kept depositing the money in an account opened jointly with his wife, incme from such joint account is his and even if shown under his wife's income, shall be clubbed as per provision of section 64 of the I T Act.

Yes, if the wife had independent income , only 50% of gains can be shown.
(9) He has had USA income for sometime in between, always being a resident of India, for which taxes have been deducted there. Does the double tax avoidance treaty hold good here?

Answer 9:Yes, article 25 of DTAA holds good.

(10) For how many years, one is expected to keep the bank/stock-broker/mutualfund /tax-deduction records?

Answer 10: The maintenance of accounts are mandatory for only specified types of persons under the I T Act. You read this .

Saturday, January 13, 2007

Grievance Cell will Take Care of refund Grievance.

Can I get I.T. Refund for A.Y. 2002-03 and 2003-04, the returns having been filed on Aug. 09, 2002 and Mar. 31, 2004, the file being of non-salary business income(mabufacturing proprietory concern). I had attached Form No. 30, and the relevant TDS Certificates in original, alongwith the return papers. I have neither received the refund, nor the assessment order till date. Kindly expedite as to the procedure for claiming the refunds? daga.akshay@.com

If refund is due, you will get not only refund but also interest upt the date of refund. You do following things

Write a letter to A.O , enclosing photocopies of return. Give a copy to the Add.CIT Range or JCIT range.
After one month, you do not receive any reply from him, write a letter to Add CIT Range giving copy to CIT of that charge.
If that also does not bring any success, write a letter to Grievance cell , giving all papers. The grievance cell is generally in the Chief Commissioner Cell.

I feel you will get refund expeditiously if you write to Grievance Cell .

q4tax

PAN is Not Mandatory for NRIs.However, Better Do It.

I would like to know that,whether a pan card is required for an NRI.actually my brother is residing in U.S.since Dec 2000.He came to India by dec 2001 for 30 days.Again he came to India during 2003 for15 days and during 2005 he came for 26 days.As of now he wants to invest in mutual funds &other investments.So I would like to know his residential status.whether he would require a pan?And whats the procedure to invest in India.Or how could he make investments in India?whether his returns through investments are taxable in India?do the needful regarding the above query. ammaialag@yahoo.com

He is Non Resident.

Strictly speaking , there is no requirements for obtaining PAN by Non Resident . This is on account of Rule 114(C)(1) of I T Rule , which says that Section 139 A of the I T Act is not applicable in case of Non-Resident. Second proviso to Rule 114B states that such person who are not required to have PAN should make declaration in Form 60 for entering into any transaction which requires mandatory mention of PAN

However, recently govt framed law to allot PAN to even Non Resident and Person of Indian origin. The detailed guideline is given vide PAN circular no 6 dated 11/10/2006 . Read it here to understand the documents required for getting the PAN.

As far as types of investment are concerned, he can invest in shares , mutual funds , in real estate and although PAN is not required as per I T Rule , it is better to get one, because this will help you in minimising hassles.Your brother can apply for PAN online from UTISL or NSDL sites.

Yes , all income out of investment in India by Non Resident is taxable unless expressly made exempt. Watch this space , I shall be putting articles on Investments by Non Resident.

One Return for 15 Months or Two Returns for Two Years?

I formed a company in January this year and have not filed the return for 31.3.2006. Can I file a combined return for 15 months or so at the end of financial year 31.3.2007?Are there any previous instances/case history?Regards,Ravi

No , there is no such provision in the I T Act . You will have to file two returns for Asst Yr 2006-07 & Asst Yr 2007-08.The return under the I T Act is to be filed for financial year .The technical term for financial year in the I T Act is Previous Year.The previous year is defined under Section 3 of I T Act .

"3. For the purposes of this Act, previous year means the financial year immediately preceding the assessment year :
Provided that, in the case of a business or profession newly set up, or a source of income newly coming into existence, in the said financial year, the previous year shall be the period beginning with the date of setting up of the business or profession or, as the case may be, the date on which the source of income newly comes into existence and ending with the said financial year."

Monday, January 08, 2007

Don't Challenge Long Hand of Law!

I use to trade in Nifty futures, till today i didnt filed my returns, now i want to file returns.generally in Nifty fut i take 1 month futures after getting expiry i shift my position to next month future, like this i trade in futures.what would be the applicable income tax % on my income in this trades?is this comes in short term capital gains or long term capital gains or it comes in general business income , why bcz here i am not getting any delivery , this my total trade is non delivery.pls say clearly about this my case with tax slabs.From: shivakassa@.com

The first thing I would like to suggest you that you must file return.Not filing of return is not beneficial to you at all from any point of view. The reasons are

if you are getting taxable income above Rs 100000[considering you have no other income] , you are breaking law .
Even if you are incurring losses, you are losing the benefit of claim of loss for adjustment in future years.
The trading these days are not without Client Code inserted at the time of trade. Your broker must be inserting these. So , your trade is not beyond the clutch of taxmen.

As far as income tax on your income is concerned, the trade in FUTURES or OPTION are NOW business activities and not speculation . There is no questions of Capital Gains in case of Derivative trading.

Therefore , compute your net gain or loss out of such trading in futures or option and if you happen to earn total income above Rs 1 lakh, file your return .

Wednesday, December 13, 2006

Oh!Great News. No Tax Audit Report or P &L Account or Balance Sheet required to be Attached with Return.

As per the CBDT,s circular No. 9/2006, dated 10-10-2006 , along with new Return forms namely -Form 2F ,Form No. 1, Form No. 2, Form No. 3, and Form No. 3B- a taxpayer should not attach

any statement showing the computation of income or tax or notes thereto,
copies of balance-sheet, profit and loss account or notes thereto,
TDS/ TCS certificate,
proof of payment of advance tax or self-assessment tax,
Tax audit report u/s 44AB,
Any other document.

Should the Tax Audit Report be submitted separately?

No, TAx Audit Report need not be furnished separately also before or after the due date. However, you must get the report of audit u/s 44AB before the due date of the furnishing of the return. You may be asked to furnish the audit report in original during the assessment proceedings. No penalty under section 271B shall be initiated or levied for not furnishing the tax audit report on or before the due date. However, if the audit report has not been obtained before the due date, provisions of section 271B shall be attracted.

What about Audit report u/s 92 E?
The report as required under section 92E of the Income-tax Act shall continue to be furnished before the date specified in rule 10E.

No TDS or TCS with Return? How will Govt give credit ?

While processing the return under section 143(1), the credit for Tax deducted at source (TDS)/ Tax collected at sources (TCS) shall be allowed on the basis of details furnished in the relevant schedules of these returns as if the TDS/ TCS certificates have been filed.

Seven Answers You Must Know About New Forms of Income Tax?

This is based on CBDT Circular No. 9/2006, dated 10-10-2006 .The Central Board of Direct Taxes have notified following new return forms for assessment year 2006-07:
(i) Form No. 2F

For resident individual or HUF having

no income from business or profession or agricultural income or
capital gains (except long-term capital gains from transactions on which securities transaction tax paid); or
not claiming relief under section 89 in respect of arrears or advance of salary;
not owning more than one house property.

(ii) Form No. 1, Form No. 2, Form No. 3, and Form No. 3B

Form No.1 is a combined form for return of income and return of fringe benefits for companies other than those claiming exemption under section 11;
Form No.2 is a combined form for return of income and return of fringe benefits for non-corporate assessees
(i) not claiming exemption under section 11, and
(ii) having income from business or profession;
Form No.3 is a form for return of income for non-corporate assessees not claiming exemption under section 11 and not having income from business or profession;
Form No.3B is a residual form for return of fringe benefits for the assessees
(i) who are required to furnish the return of income and also the return of fringe benefits but have filed the return of income in Form No. 1 or Form No. 2 or Form No. 2D or Form No. 3A for the Assessment Year 2006-07 before the notification of this Form No. 3B, or opts to file the return of income in Form No. 2D
(ii) who are not required to furnish the return of income but are required to furnish the return of fringe benefits.

What to do if I have to file return for earlier years ?
If a taxpayer intends to file a return for any earlier assessment year he will have to use the old forms.

I have got Digital Signature . Do I have to file paper return ?
No , in that case no paper return is required to be filed.

I do not have Digital Signature .What to to do?
In that case :

First step is to transmit the details of the return and schedules thereto electronically (without digital signature) to the designated web-site
Second Stepp is to file a paper Return.

The date of the electronic transmission and acknowledgement number given electronically by the Income-tax Department for such transmission has to be filled in the paper return.

Is there any other method of filing Return of Income?
Yes, you may also file, an e-return in accordance with following schemes:
(i) through e-Return Intermediary, followed by a paper return. The scheme is applicable to all class of taxpayers who are assessed or assessable to tax at any of the cities specified in Schedule A of the Scheme (i.e. net-worked cities);
(ii) Furnishing of Return of Income Internet Scheme, 2004. [Notified vide SO No. 1074(E) dated 30-9-2004] Under this Scheme, e-return has to be filed under the digital signature. The scheme is applicable only to individual taxpayers who has income under the head Salaries but does not have any income under the head Profits and gains of business or profession and who are assessed or assessable to tax at any of the cities specified in Schedule A of the Scheme (i.e. net-worked cities);

What will be the date of filing of Return?

In case, a return is furnished under digital signature, the date of such furnishing shall be the date of furnishing the return-.
In case, a return is furnished under two- step procedure -the date of furnishing the e-return will be the date of furnishing the return only if
(a) paper return has been filed within fifteen days from the date of filing the e-return or within one month from the date of issue of this Circular, whichever is later; and
(b) paper return tallies with the e-return.
In case condition in (a) or (b) above is not satisfied, the paper return shall be taken to be the return and date of filing the paper return shall be taken as the date of filing the return.
Where to file the Return ?
The e-Return has to be filed at http://incometaxindiaefiling.gov.in.The paper return, if any, in respect of such e-returns shall be filed either at separate counter(s) to be set up for this purpose at each local income-tax office (whether on net-work or not) or at designated postal offices.

Sunday, December 10, 2006

Gift of Assets to HUF will not reduce Tax Liability!

CAN MEMBERS OF THE FAMILY TRANSFER MONEY TO HUF WITHOUTANY TAX LIABILITY TO HUF?CAN MY MOTHER / MOTHER IN LAWGIVE A GIFT TO MY HUF ACCOUNT? From: spinamdar@.....com
If relatives ,as deifned in Explanation below Section 56[2][v],transfer money to HUF , the same shall not be taxable in the hand sof HUfas per Section 56[2][v] of the I T Act.However,the income generated out of such assets given in Gift ,is without consideration,therefore shall be added to the income of the individual who gifted such an asset as per section 64[2][a]and [b] of the I T Act.
Sub -Section 2 of Section 64 states " Where, in the case of an individual being a member of a Hindu undivided family, any property having been the separate property of the individual has, at any time after the 31st day of December,1969, been converted by the individual into property belonging to the family through the act of impressing such separate property with the character of property belonging to the family or throwing it 73[into the common stock of the family or been transferred by the individual, directly or indirectly, to the family otherwise than for adequate consideration (the property so converted or transferred being hereinafter referred to as the converted property)], then, Notwithstanding anything contained in any other provision of this Act or in any other law for the time being in force, for the purpose of computation of the total income of the individual under this Act for any assessment year commencing on or after the 1st day of April, 1971,"
The word property has been explaned in Explantion given at the end of Section 64 is below For the purposes of sub-section (2)," property includes any interest in property,movable or immovable, the proceeds of sale thereof and any money or investment for the time being representing the proceeds of sale thereof and where the property is converted into any other property by any method, such other property"

Thursday, December 07, 2006

Yes,A.O has that power.

Can the assessing officer make an assessment u/s143(3) even when assessment has been made u/s144? From: richatulsyan@.....com

Yes in one case , he can do .That is , if he rejects the accounts of the assessee under section 145[3] of the I T act. The said sub-section states

"145(3) Where the Assessing Officer is not satisfied about the correctness or completeness of the accounts of the assessee, or where the method of accounting provided in sub-section (1) or accounting standards as notified under sub-section (2), have not been regularly followed by the assessee, the Assessing Officer may make an assessment in the manner provided in section 144."

In such case, the assessment can be passed under section 143[3] , still assessment of total income can be done in the manner provided in Section 144 i.e the A.O will apply best judgment for determining total income of the assessee.

This is different than passing an order under section 144 which happens in following three circumstance

"If any person

(a) fails to make the return required under sub-section (1) of section 139 and has not made a return or a revised return under sub-section (4) or sub-section (5) of that section, or

(b) fails to comply with all the terms of a notice issued under sub-section (1) of section 142 or fails to comply with a direction issued under sub-section (2A) of that section or

(c) having made a return, fails to comply with all the terms of a notice issued under sub-section (2) of section 143."

Last thing to remember- the order of A.O will not be vitiated simply because he wrote in the assessment order section 143 instead of section 144 , because CIT[A] and ITAT are primarily fact finding authority , hence rather than a technical mistake, they will rather go in the substance of the order .

Monday, November 27, 2006

Salary in Cash over Rs 20000 falls under Section 40A[3].

If a person is receiving a salary of around Rs 20,000 per month can he be paid in cash ? His TDS etc will be deducted as per the existing norms and will his employer face any problems if the person is paid fornightly, after the requisite TDS deductions, in Cash ? From: ..................kuttimukund@.....com

Section 40[A][3] of the I T Act which make it mandatory to make payment in case of business expendiure above Rs 20000 in cash , is also applicable on Salary. Thus ,if the payment is made above Rs 20000 , which may happen in case if Fortnightly payments, the A.O may disallow 20% of such payments.
I feel it is prudent not to give controversy to the issue, and better that pay the amount of salary by account Cheque or Draft.

Sunday, September 03, 2006

Six months have passed since I received the assessment order . I forgot to appeal before CIT(Appeal).Can I file appeal now?

Normally, the law provides u/s 249 that Appeal shall be filed within 30 days from the receipt of the order of the Assessing Officer. However , u/s 249(3) provides that CIT(A) may condone the delay if he founds that the appellant was prevented from filing appeal due to genuine reasons.
You can also get relief by filing an application u/s 264 before the jurisdictional Commissioner of Tax for quashing the order passed by the A.O. The time limit for filing appeal u/s 264 of the I T Act is ONE year from the date of receipt of the order. So you can , Still file , an appeal u/s 264 before the Commissioner of Income Tax .
Remember, if you file an appeal before CIT(A) , you can not file simultaneous application u/s 264 before the CIT. Only either of them can have your petition.

Subscribe to: Posts (Atom)