text:
Exotic crystal semiconductor may lead to better solar cells
By Paul Heney | May 17, 2019
A conceptual view of a transistor device that controls photoluminescence (red cone) emitted by a hybrid perovskite crystal (red box) that is excited by a blue laser beam after voltage is applied to an electrode (the gate).
Scientists have found a new way to control light emitted by exotic crystal semiconductors, and this finding might lead to more efficient solar cells as well as other advances in electronics, according to a Rutgers-led study in the journal Materials Today.
The discovery involves crystals called hybrid perovskites, which consist of interlocking organic and inorganic materials that have shown great promise for use in solar cells. The finding could also lead to novel electronic displays, sensors and other devices activated by light and bring increased efficiency at a lower cost to manufacturing of optoelectronics, which harness light.
The team found a new way to control light (known as photoluminescence) emitted when perovskites are excited by a laser. The intensity of light emitted by a hybrid perovskite crystal can be increased by up to 100 times, simply by adjusting voltage applied to an electrode on the crystal surface.
"To the best of our knowledge, this is the first time that the photoluminescence of a material has been reversibly controlled to such a wide degree with voltage," said senior author Vitaly Podzorov, a professor in the Department of Physics and Astronomy in the School of Arts and Sciences at Rutgers University–New Brunswick. "Previously, to change the intensity of photoluminescence, you had to change the temperature or apply enormous pressure to a crystal, which was cumbersome and costly. We can do it simply within a small electronic device at room temperature."
Semiconductors like these perovskites have properties that lie between those of the metals that conduct electricity and non-conducting insulators. Their conductivity can be tuned in a very wide range, making them indispensable for all modern electronics.
"All the wonderful modern electronic gadgets and technologies we enjoy today, be it a smartphone, a memory stick, powerful telecommunications and the internet, high-resolution cameras or supercomputers, have become possible largely due to the decades of painstaking research in semiconductor physics," Podzorov said.
Understanding photoluminescence is important for designing devices that control, generate or detect light, including solar cells, LED lights and light sensors. The scientists discovered that defects in crystals reduce the emission of light and applying voltage restores the intensity of photoluminescence.
Hybrid perovskites are more efficient — and much easier and cheaper to make — than standard commercial silicon-based solar cells, and the study could help lead to their widespread use, Podzorov said. An important next step would be to investigate different types of perovskite materials, which may lead to better and more efficient materials in which photoluminescence can be controlled in a wider range of intensities or with smaller voltage.
Filed Under: TECHNOLOGIES + PRODUCTS, Design World articles, Semiconductor, Green engineering
Paul Heney
Paul J. Heney, the VP, Editorial Director for Design World magazine, has a BS in Engineering Science & Mechanics and minors in Technical Communications and Biomedical Engineering from Georgia Tech. He has written about fluid power, aerospace, robotics, medical, green engineering, and general manufacturing topics for nearly 25 years. He has won numerous regional and national awards for his writing from the American Society of Business Publication Editors.
The end of the old plastic bottle?
Material testing for lithium-ion batteries
Seals help in hydrogen production via electrolysis
Keeping cool with capacitors


text:
Divorce Season 1: Release Date and Speculations, Sarah Jessica Parker Starring in Another HBO Series
Divorce Season 1:American television comedy series Divorce developed by Sharon Horgan is all geared up to make its grand premiere on HBO on October 9, 2016, with its very first season. The trailers and the promos of Divorce Season 1 which were released few months back created quite a lot of buzz among the viewers. As it stars the popular 'Sex and the City' actress Sarah Jessica Parker and the 'Wings' actor Thomas Haden Church. The viewers will get to see Sarah and Thomas sharing the same screen space after almost eight years, as they were witnessed starring together in Noam Murro's Smart People in 2008. However, Sarah will be seen on the small screen after ages as she was last seen depicting the character of Carrie Bradshaw in Sex and the City which was also telecasted on HBO.
As per the trailer and the promos of Divorce Season 1 the series seem to add humour in between the disturbed relationship of a couple. The depiction of how Sarah is utterly irritated with the deeds of her husband is absolutely hilarious. And when Thomas asks her "When did it start to go off the tracks?" Jessica's reply was extremely side-splitting as she responded saying "perhaps when you grew the moustache". There comes a scenario in the promo when both of them ignore each other by showing the middle finger also seemed to be immensely amusing. However, the viewers are now waiting to release their curiosity buds with the premiere of Divorce Season 1. And are expecting Sarah and Thomas to do utmost justice to the plotline of the series with their outstanding acting prowess.
Sarah was highly acknowledged for her role in Sex and the City. It fetched her innumerable number of fan following. And now all her fans are looking forward to watch her performance in Divorce Season 1. Nevertheless, the portrayal of hilarious scenarios of a disturbed couple would be a treat for the eyes for the viewers for sure.
TagsDivorce Season 1Sarah Jessica ParkerThomas Haden Church
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redpajama_set_name: RedPajamaCommonCrawl


text:
Apple Music Reportedly Surpasses Spotify In US Subscribers
by Brandon Hill — Friday, July 06, 2018, 02:16 PM EDT
When it comes to digital music, streaming is king. Just a few years ago, it seemed as though we were all resigned to paying 99 cents per song or $10 for individual albums (thanks to Apple's iTunes push). However, the all-you-can-eat streaming music buffet is hard to ignore. We're now learning that Apple Music has surpassed reigning streaming music champ Spotify in U.S. subscriber numbers, which is a huge achievement for the service that launched nearly three years ago.
The latest figures come courtesy of Digital Music News, which says that both Apple Music and Spotify have over 20 million paid subscribers in the United States alone. In the case of Apple Music, it is a "hair ahead" of Spotify.
"The data for 2018 also shows that Apple is experiencing a far stronger rate-of-growth in the United States," writes Digital Music News. According to the publication, Apple is on track to significantly grow its lead over Spotify through the end of 2018. Reports earlier this year pegged Apple Music's subscriber growth at 5 percent per month, more than double that of Spotify.
When it comes to total subscriber numbers though, Spotify still has the upper hand -- by far. According to a financial disclosure in March, Spotify has 75 million paying subscribers globally and a total of 170 million active users.
Back in mid-May, Apple CEO Tim Cook confirmed that Apple Music had over 50 million active users globally (roughly 40 million of those are paid subscribers). That was up from 38 million total subscribers globally in March and 40 million in April. It may be a while still before Apple Music is able to topple Spotify in overall paid and total subscribers, but it is well on its way.
Tags: spotify, (NASDAQ:AAPL), apple music, (nyse:spot)


text:
Q: How to get runtime value of column and used in the next row I have below dataframe, based on the visited date I need to create a new column allowed- If the customar visted within a week from last allowd week visit I have to mark allowed as NO (4th row 2020-01-09-2020-01-10 <7 ) and if it is more than 1 week allowed yes (3rd row 2020-01-09-2020-01-01 >7 )
Input DF
Customar  visited_date

John       2020-01-01
John       2020-01-05
John       2020-01-09
John       2020-01-10
John       2020-01-17

output DF
Customar  visited_date allowed

John       2020-01-01   Yes
John       2020-01-05   No
John       2020-01-09   Yes
John       2020-01-10   No
John       2020-01-17   Yes

I dont know how to calulate the colum value in runtime and used that in subsequent column calculation.

redpajama_set_name: RedPajamaStackExchange


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Overwhelmed on a daily basis?
As a child raised in an ultra-productive home, I was involved with many extra-curricular activities and grew up living in a constant hurry from one thing to the next.
Once I graduated from college, I had no idea how to function without an overwhelming busy schedule. My anxiety would increase whenever I had a moment to catch my breath and get in tune with my body, mind and soul.
After a short time though, I got burnt out. I became physically ill, crabby, and emotionally drained.
Little by little, I began to crave space.
The problem was: I didn't know how to change the pace of my life. I knew I needed a drastic changes, but even when I tried to make changes it was only a matter of time before the busyness took over and I was back to the life I was never created to live.
One day, in August of 2018, something snapped in me. I went for a jog and prayed to God about my desire for less chaos and more peace in my life. The word "space" kept coming up and I couldn't ignore it. Unlike ever before, God placed a very clear call on my heart.
I was supposed to create space, and a lot of it.
I immediately hurried home and told my husband, who, naturally, laughed. After all, I was a "yes" woman, who rarely ever said no to things. I was a busybody and a chatterbox. Going slow and sitting in silence were foreign to me.
The entire next month was focused on claiming space, creating space, and using space well.
The transformation I experienced because of space was unbelievable.
The best part? It's transformation that goes far beyond the surface.
Now, I spend a good chunk of my life leading other women to live spacious lives.
I want to help you create space in your life and grow closer to God because of it.
We are taking my Space Workshop to four Midwest cities in the month of May. Nothing says you are more serious about creating space in your life than blocking out a Saturday morning to focus on just that.
Grab your mom, sister, a girlfriend and meet me there?!


It's easy for a prospective new car buyer to allow logic to go out the window the minute they step onto the auto dealer's lot. Don't let your emotion get the best of you when you see all of those shiny new cars equipped with plenty of fancy features. If you don't plan ahead and know the 6 essential questions new car buyers need to ask, you may just find yourself winding up with a lemon.
1. Can I Take the Car On A Test Drive?
No matter how handsome a new car make look on the dealer's showroom floor, you won't really know how it handles until you get the car out on the road and into some daily traffic. A test drive not only allows you to experience firsthand how the car handles and sounds at a variety of speeds, you will also find out if the seating is comfortable and if the amount of space and special features included are exactly those that meet your needs.
2. Has This Car Ever Been Damaged?
North Shore Driving School Ltd is a driving school that is up in Vancouver. They have a pretty helpful blog and this particular question was addressed furthing the importance of making sure that this question is being asked! Even if you are buying a brand new car, there are several instances where your car could be damaged. During the shipping process, even a new automobile may sustain scrapes to its finish that have been covered up with a good paint job. This is also the right time to inquire if the car has been used as a demo or dealer's car. If so, there may already be wear and tear on the automobile which will affect its looks or performance. You obviously don't want to pay new car prices for a new car that already has several hundred miles on the odometer.
3. What Warranty Coverage is Included?
Be very clear about exactly what you will be responsible for paying in the way of maintenance and repairs during your first few years of car ownership. Determine whether any free maintenance services are included.
4. Where Will I Be Able to Get Repair Service?
Some dealers have their own in-house service centers and handle regular maintenance and repairs themselves. Figure out if that location is convenient to your home and whether you can take the vehicle to other authorized service centers.
5. What About After-Market Add-Ons?
Find out if the vehicle already has such add-ons as window tinting, theft recovery system or mud flaps that increase the purchase price and may be expensive to maintain.
6. What's The Actual Cost of the Car?
Asking this question provides you with the real picture of what you'll be paying, including fees and licensing, versus simply talking about low monthly payments.
New car buyers are much more likely to get the best deal and no unhappy surprises by asking these six essential questions before purchasing a new car.


text:
Q: VBA Scenario Deleter Macro only Deletes odd macros Hello I wrote a VBA Macro to delete my What if Scenarios I have 84 of them and they are named 1,2,3,4,....,84 so I wrote this code
Sub Dismantle()
For Count = 1 To 84
    ActiveSheet.Scenarios(Count).Delete
Next

End Sub

But it only deletes scenarios 1,3,5,7,9.....,83 then returns the error: Unable to get Scenarios property of the worksheet class.
This means there is no scenario with the name count for it to delete (I think anyway)
Running again it deletes the first third ect again so its skipping every second scenario.

A: Sub Dismantle()
    For Count = 84 to 1 step -1
        ActiveSheet.Scenarios(Count).Delete
    Next
End Sub

You were so close :-)
Or, for more flexibility:
Do While ActiveSheet.Scenarios.Count > 0
    ActiveSheet.Scenarios(1).Delete()
Loop


text:
#include "ruby_gdiplus.h"

const rb_data_type_t tMatrix = _MAKE_DATA_TYPE(
    "Matrix", 0, GDIP_OBJ_FREE(Matrix *), NULL, NULL, &cMatrix);

static VALUE
gdip_matrix_create(Matrix *matrix)
{
    VALUE v_matrix = typeddata_alloc_null<&tMatrix>(cMatrix);
    _DATA_PTR(v_matrix) = gdip_obj_create(matrix);
    return v_matrix;
}

/**
 * @overload initialize()
 * @overload initialize(rect, points)
 *   @param rect [Rectangle]
 *   @param points [Array<Point>] the upper-left, upper-right, and lower-left corners of the rectangle
 * @overload initialize(rect, points)
 *   @param rect [RectangleF]
 *   @param points [Array<PointF>] the upper-left, upper-right, and lower-left corners of the rectangle
 * @overload initialize(m11, m12, m21, m22, dx, dy)
 *   @param m11 [Float]
 *   @param m12 [Float]
 *   @param m21 [Float]
 *   @param m22 [Float]
 *   @param dx [Float]
 *   @param dy [Float]
 */
static VALUE
gdip_matrix_init(int argc, VALUE *argv, VALUE self)
{
    if (_DATA_PTR(self) != NULL) {
        _VERBOSE("This Matrix object is aloready initialized.");
        return self;
    }

    if (argc != 0 && argc != 2 && argc != 6) {
        rb_raise(rb_eArgError, "wrong number of arguments (%d for 0, 2 or 6)", argc);
    }

    if (argc == 0) {
        _DATA_PTR(self) = gdip_obj_create(new Matrix());
    }
    else if (argc == 2) {
        if (_KIND_OF(argv[0], &tRectangle)) {
            int count = 0;
            Point *points = alloc_array_of<Point, &tPoint>(argv[1], count);
            if (count >= 3) {
                Rect *rect = Data_Ptr<Rect *>(argv[0]);
                Matrix *matrix = new Matrix(*rect, points);
                ruby_xfree(points);
                _DATA_PTR(self) = gdip_obj_create(matrix);
            }
            else {
                ruby_xfree(points);
                rb_raise(rb_eArgError, "The second argument should be Array with three Point.");
            }
        }
        else if (_KIND_OF(argv[0], &tRectangleF)) {
            int count = 0;
            PointF *points = alloc_array_of<PointF, &tPointF>(argv[1], count);
            if (count >= 3) {
                RectF *rect = Data_Ptr<RectF *>(argv[0]);
                Matrix *matrix = new Matrix(*rect, points);
                ruby_xfree(points);
                _DATA_PTR(self) = gdip_obj_create(matrix);
            }
            else {
                ruby_xfree(points);
                rb_raise(rb_eArgError, "The second argument should be Array with three Point.");
            }
        }
        else {
            rb_raise(rb_eTypeError, "The first argument should be Rectangle or RectangleF.");
        }
    }
    else if (argc == 6) {
        if (Float_p(6, argv)) {
            _DATA_PTR(self) = gdip_obj_create(new Matrix(
                    NUM2SINGLE(argv[0]), NUM2SINGLE(argv[1]),
                    NUM2SINGLE(argv[2]), NUM2SINGLE(argv[3]),
                    NUM2SINGLE(argv[4]), NUM2SINGLE(argv[5]) ));
        }
        else {
            rb_raise(rb_eTypeError, "The arguments should be Float.");
        }
    }

    return self;
}

static VALUE
gdip_matrix_clone(VALUE self)
{
    Matrix *matrix = Data_Ptr<Matrix *>(self);
    Check_NULL(matrix, "This Matrix object does not exist.");

    return gdip_matrix_create(matrix->Clone());
}

/**
 * Gets the elements of this Matrix.
 * @return [Array<Float>]
 */
static VALUE
gdip_matrix_get_elements(VALUE self)
{
    Matrix *matrix = Data_Ptr<Matrix *>(self);
    Check_NULL(matrix, "This Matrix object does not exist.");

    float elems[6];
    Status status = matrix->GetElements(elems);
    Check_Status(status);

    VALUE r = rb_ary_new_capa(6);
    for (int i = 0; i < 6; ++i) {
        rb_ary_push(r, SINGLE2NUM(elems[i]));
    }

    return r;
}

/**
 * Gets whether this matrix is identity matrix.
 * @return [Boolean]
 */
static VALUE
gdip_matrix_get_is_identity(VALUE self)
{
    Matrix *matrix = Data_Ptr<Matrix *>(self);
    Check_NULL(matrix, "This Matrix object does not exist.");

    return matrix->IsIdentity() ? Qtrue : Qfalse;
}

/**
 * Gets whether this matrix is invertible.
 * @return [Boolean]
 */
static VALUE
gdip_matrix_get_is_invertible(VALUE self)
{
    Matrix *matrix = Data_Ptr<Matrix *>(self);
    Check_NULL(matrix, "This Matrix object does not exist.");

    return matrix->IsInvertible() ? Qtrue : Qfalse;
}

/**
 * Gets the dx value.
 * @return [Float]
 */
static VALUE
gdip_matrix_get_offset_x(VALUE self)
{
    Matrix *matrix = Data_Ptr<Matrix *>(self);
    Check_NULL(matrix, "This Matrix object does not exist.");

    return SINGLE2NUM(matrix->OffsetX());
}

/**
 * Gets the dy value.
 * @return [Float]
 */
static VALUE
gdip_matrix_get_offset_y(VALUE self)
{
    Matrix *matrix = Data_Ptr<Matrix *>(self);
    Check_NULL(matrix, "This Matrix object does not exist.");

    return SINGLE2NUM(matrix->OffsetY());
}

/**
 * Compares with another matrix.
 * @return [Boolean]
 */
static VALUE
gdip_matrix_equal(VALUE self, VALUE other)
{
    if (self == other) return true;
    else if (_KIND_OF(other, &tMatrix)) {
        Matrix *matrix_self = Data_Ptr<Matrix *>(self);
        Check_NULL(matrix_self, "This Matrix object does not exist.");

        Matrix *matrix_other = Data_Ptr<Matrix *>(other);
        Check_NULL(matrix_other, "The argument Matrix object does not exist.");

        return matrix_self->Equals(matrix_other) ? Qtrue : Qfalse;
    }
    else return false;
}

/**
 * Multiplies two matrices.
 * @return [self]
 */
static VALUE
gdip_matrix_multiply(int argc, VALUE *argv, VALUE self)
{
    Check_Frozen(self);
    Matrix *matrix_self = Data_Ptr<Matrix *>(self);
    Check_NULL(matrix_self, "This Matrix object does not exist.");

    VALUE v_other;
    VALUE v_order;
    rb_scan_args(argc, argv, "11", &v_other, &v_order);

    MatrixOrder order = MatrixOrderPrepend;
    if (!RB_NIL_P(v_order)) {
        gdip_arg_to_enumint(cMatrixOrder, v_order, &order, "The second argument should be MatrixOrder.");
    }

    if (_KIND_OF(v_other, &tMatrix)) {
        Matrix *matrix_other = Data_Ptr<Matrix *>(v_other);
        Check_NULL(matrix_other, "The argument Matrix object does not exist.");

        Status status = matrix_self->Multiply(matrix_other, order);
        Check_Status(status);
    }
    else {
        rb_raise(rb_eTypeError, "The first argument should be Matrix.");
    }

    return self;
}

/**
 * Inverts this Matrix.
 * @return [self]
 */
static VALUE
gdip_matrix_invert(VALUE self)
{
    Check_Frozen(self);
    Matrix *matrix = Data_Ptr<Matrix *>(self);
    Check_NULL(matrix, "This Matrix object does not exist.");

    Check_Status(matrix->Invert());
    return self;
}

/**
 * Resets this matrix to identity matrix.
 * @return [self]
 */
static VALUE
gdip_matrix_reset(VALUE self)
{
    Check_Frozen(self);
    Matrix *matrix = Data_Ptr<Matrix *>(self);
    Check_NULL(matrix, "This Matrix object does not exist.");

    Check_Status(matrix->Reset());
    return self;
}

/**
 * Rotates by the specified angle.
 * @overload Rotate(angle, order=MatrixOrder.Prepend)
 *   @param angle [Float] The rotation angle, in degrees.
 *   @param order [MatrixOrder]
 *   @return [self]
 */
static VALUE
gdip_matrix_rotate(int argc, VALUE *argv, VALUE self)
{
    Check_Frozen(self);
    Matrix *matrix = Data_Ptr<Matrix *>(self);
    Check_NULL(matrix, "This Matrix object does not exist.");

    VALUE v_angle;
    VALUE v_order;
    rb_scan_args(argc, argv, "11", &v_angle, &v_order);

    float angle = 0.0f;
    gdip_arg_to_single(v_angle, &angle, "The argument should be Float or Integer.");

    MatrixOrder order = MatrixOrderPrepend;
    if (!RB_NIL_P(v_order)) {
        gdip_arg_to_enumint(cMatrixOrder, v_order, &order, "The second argument should be MatrixOrder.");
    }

    Status status = matrix->Rotate(angle, order);
    Check_Status(status);

    return self;
}

/**
 * Rotates by the specified angle around the given point.
 * @overload RotateAt(angle, point, order=MatrixOrder.Prepend)
 *   @param angle [Float] The rotation angle, in degrees.
 *   @param point [PointF or Point]
 *   @param order [MatrixOrder]
 *   @return [self]
 */
static VALUE
gdip_matrix_rotate_at(int argc, VALUE *argv, VALUE self)
{
    Check_Frozen(self);
    Matrix *matrix = Data_Ptr<Matrix *>(self);
    Check_NULL(matrix, "This Matrix object does not exist.");

    VALUE v_angle;
    VALUE v_point;
    VALUE v_order;
    rb_scan_args(argc, argv, "21", &v_angle, &v_point, &v_order);

    float angle = 0.0f;
    gdip_arg_to_single(v_angle, &angle, "The argument should be Float or Integer.");

    MatrixOrder order = MatrixOrderPrepend;
    if (!RB_NIL_P(v_order)) {
        gdip_arg_to_enumint(cMatrixOrder, v_order, &order, "The second argument should be MatrixOrder.");
    }

    Status status = Ok;
    if (_KIND_OF(v_point, &tPointF)) {
        PointF *point = Data_Ptr<PointF *>(v_point);
        status = matrix->RotateAt(angle, *point, order);
    }
    else if (_KIND_OF(v_point, &tPoint)) {
        Point *point_i = Data_Ptr<Point *>(v_point);
        PointF point;
        point.X = static_cast<float>(point_i->X);
        point.Y = static_cast<float>(point_i->Y);
        status = matrix->RotateAt(angle, point, order);
    }
    else {
        rb_raise(rb_eTypeError, "The second argument should be PointF or Point.");
    }
    Check_Status(status);

    return self;
}

/**
 * Scales to the specified scale.
 * @overload Scale(scale_x, scale_y, order=MatrixOrder.Prepend)
 *   @param scale_x [Float]
 *   @param scale_y [Float]
 *   @param order [MatrixOrder]
 *   @return [self]
 */
static VALUE
gdip_matrix_scale(int argc, VALUE *argv, VALUE self)
{
    Check_Frozen(self);
    Matrix *matrix = Data_Ptr<Matrix *>(self);
    Check_NULL(matrix, "This Matrix object does not exist.");

    VALUE v_scale_x, v_scale_y, v_order;
    rb_scan_args(argc, argv, "21", &v_scale_x, &v_scale_y, &v_order);

    float scale_x = 0.0f;
    float scale_y = 0.0f;
    gdip_arg_to_single(v_scale_x, &scale_x, "The first argument should be Float or Integer.");
    gdip_arg_to_single(v_scale_y, &scale_y, "The second argument should be Float or Integer.");

    MatrixOrder order = MatrixOrderPrepend;
    if (!RB_NIL_P(v_order)) {
        gdip_arg_to_enumint(cMatrixOrder, v_order, &order, "The second argument should be MatrixOrder.");
    }

    Status status = matrix->Scale(scale_x, scale_y, order);
    Check_Status(status);

    return self;
}

/**
 * Shears.
 * @overload Shear(shear_x, shear_y, order=MatrixOrder.Prepend)
 *   @param shear_x [Float]
 *   @param shear_y [Float]
 *   @param order [MatrixOrder]
 *   @return [self]
 */
static VALUE
gdip_matrix_shear(int argc, VALUE *argv, VALUE self)
{
    Check_Frozen(self);
    Matrix *matrix = Data_Ptr<Matrix *>(self);
    Check_NULL(matrix, "This Matrix object does not exist.");

    VALUE v_shear_x, v_shear_y, v_order;
    rb_scan_args(argc, argv, "21", &v_shear_x, &v_shear_y, &v_order);

    float shear_x = 0.0f;
    float shear_y = 0.0f;
    gdip_arg_to_single(v_shear_x, &shear_x, "The first argument should be Float or Integer.");
    gdip_arg_to_single(v_shear_y, &shear_y, "The second argument should be Float or Integer.");

    MatrixOrder order = MatrixOrderPrepend;
    if (!RB_NIL_P(v_order)) {
        gdip_arg_to_enumint(cMatrixOrder, v_order, &order, "The second argument should be MatrixOrder.");
    }

    Status status = matrix->Shear(shear_x, shear_y, order);
    Check_Status(status);

    return self;
}

/**
 * Translates.
 * @overload Translate(offset_x, offset_y, order=MatrixOrder.Prepend)
 *   @param offset_x [Float]
 *   @param offset_y [Float]
 *   @param order [MatrixOrder]
 *   @return [self]
 */
static VALUE
gdip_matrix_translate(int argc, VALUE *argv, VALUE self)
{
    Check_Frozen(self);
    Matrix *matrix = Data_Ptr<Matrix *>(self);
    Check_NULL(matrix, "This Matrix object does not exist.");

    VALUE v_offset_x, v_offset_y, v_order;
    rb_scan_args(argc, argv, "21", &v_offset_x, &v_offset_y, &v_order);

    float offset_x = 0.0f;
    float offset_y = 0.0f;
    gdip_arg_to_single(v_offset_x, &offset_x, "The first argument should be Float or Integer.");
    gdip_arg_to_single(v_offset_y, &offset_y, "The second argument should be Float or Integer.");

    MatrixOrder order = MatrixOrderPrepend;
    if (!RB_NIL_P(v_order)) {
        gdip_arg_to_enumint(cMatrixOrder, v_order, &order, "The second argument should be MatrixOrder.");
    }

    Status status = matrix->Translate(offset_x, offset_y, order);
    Check_Status(status);

    return self;
}

/**
 * @overload TransformPoints(points)
 *   Returns the result of applying this matrix to the specified points.
 *   @param points[Array<Point or PointF>]
 *   @return [Array<Point or PointF>]
 */
static VALUE
gdip_matrix_transform_points(VALUE self, VALUE v_points)
{
    Matrix *matrix = Data_Ptr<Matrix *>(self);
    Check_NULL(matrix, "This Matrix object does not exist.");

    if (!_RB_ARRAY_P(v_points) || RARRAY_LEN(v_points) < 1) {
        rb_raise(rb_eTypeError, "The arguments should be Array of Point or PointF.");
    }

    VALUE r = Qnil;
    VALUE first = rb_ary_entry(v_points, 0);
    Status status = Ok;
    if (_KIND_OF(first, &tPoint)) {
        int count = 0;
        Point *points = alloc_array_of<Point, &tPoint>(v_points, count);
        status = matrix->TransformPoints(points, count);
        r = rb_ary_new_capa(count);
        for (int i = 0; i < count; ++i) {
            rb_ary_push(r, gdip_point_create(points[i].X, points[i].Y));
        }
        ruby_xfree(points);
    }
    else if (_KIND_OF(first, &tPointF)) {
        int count = 0;
        PointF *points = alloc_array_of<PointF, &tPointF>(v_points, count);
        status = matrix->TransformPoints(points, count);
        r = rb_ary_new_capa(count);
        for (int i = 0; i < count; ++i) {
            rb_ary_push(r, gdip_pointf_create(points[i].X, points[i].Y));
        }
        ruby_xfree(points);
    }
    else {
        rb_raise(rb_eTypeError, "The arguments should be Array of Point or PointF.");
    }
    Check_Status(status);

    return r;
}

/**
 * @overload TransformVectors(points)
 *   Returns the result of applying this matrix excluding translation to the specified points, ignoring translation (dx, dy).
 *   @param points[Array<Point or PointF>]
 *   @return [Array<Point or PointF>]
 */
static VALUE
gdip_matrix_transform_vectors(VALUE self, VALUE v_points)
{
    Matrix *matrix = Data_Ptr<Matrix *>(self);
    Check_NULL(matrix, "This Matrix object does not exist.");

    if (!_RB_ARRAY_P(v_points) || RARRAY_LEN(v_points) < 1) {
        rb_raise(rb_eTypeError, "The arguments should be Array of Point or PointF.");
    }

    VALUE r = Qnil;
    VALUE first = rb_ary_entry(v_points, 0);
    Status status = Ok;
    if (_KIND_OF(first, &tPoint)) {
        int count = 0;
        Point *points = alloc_array_of<Point, &tPoint>(v_points, count);
        status = matrix->TransformVectors(points, count);
        r = rb_ary_new_capa(count);
        for (int i = 0; i < count; ++i) {
            rb_ary_push(r, gdip_point_create(points[i].X, points[i].Y));
        }
        ruby_xfree(points);
    }
    else if (_KIND_OF(first, &tPointF)) {
        int count = 0;
        PointF *points = alloc_array_of<PointF, &tPointF>(v_points, count);
        status = matrix->TransformVectors(points, count);
        r = rb_ary_new_capa(count);
        for (int i = 0; i < count; ++i) {
            rb_ary_push(r, gdip_pointf_create(points[i].X, points[i].Y));
        }
        ruby_xfree(points);
    }
    else {
        rb_raise(rb_eTypeError, "The arguments should be Array of Point or PointF.");
    }
    Check_Status(status);

    return r;
}

void
Init_matrix()
{
    cMatrix = rb_define_class_under(mGdiplus, "Matrix", cGpObject);
    rb_define_alloc_func(cMatrix, &typeddata_alloc_null<&tMatrix>);
    rb_define_method(cMatrix, "initialize", RUBY_METHOD_FUNC(gdip_matrix_init), -1);
    ATTR_R(cMatrix, Elements, elements, matrix);
    ATTR_R_Q(cMatrix, IsIdentity, is_identity, matrix);
    ATTR_R_Q(cMatrix, IsInvertible, is_invertible, matrix);
    ATTR_R(cMatrix, OffsetX, offset_x, matrix);
    ATTR_R(cMatrix, OffsetY, offset_y, matrix);

    rb_define_method(cMatrix, "==", RUBY_METHOD_FUNC(gdip_matrix_equal), 1);
    rb_define_method(cMatrix, "Clone", RUBY_METHOD_FUNC(gdip_matrix_clone), 0);
    rb_define_alias(cMatrix, "clone", "Clone");
    rb_define_alias(cMatrix, "dup", "Clone");

    rb_define_method(cMatrix, "Multiply", RUBY_METHOD_FUNC(gdip_matrix_multiply), -1);
    rb_define_alias(cMatrix, "multiply", "Multiply");
    rb_define_method(cMatrix, "Invert", RUBY_METHOD_FUNC(gdip_matrix_invert), 0);
    rb_define_alias(cMatrix, "invert", "Invert");
    rb_define_method(cMatrix, "Reset", RUBY_METHOD_FUNC(gdip_matrix_reset), 0);
    rb_define_alias(cMatrix, "reset", "Reset");
    rb_define_method(cMatrix, "Rotate", RUBY_METHOD_FUNC(gdip_matrix_rotate), -1);
    rb_define_alias(cMatrix, "rotate", "Rotate");
    rb_define_method(cMatrix, "RotateAt", RUBY_METHOD_FUNC(gdip_matrix_rotate_at), -1);
    rb_define_alias(cMatrix, "rotate_at", "RotateAt");
    rb_define_method(cMatrix, "Scale", RUBY_METHOD_FUNC(gdip_matrix_scale), -1);
    rb_define_alias(cMatrix, "scale", "Scale");
    rb_define_method(cMatrix, "Shear", RUBY_METHOD_FUNC(gdip_matrix_shear), -1);
    rb_define_alias(cMatrix, "shear", "Shear");
    rb_define_method(cMatrix, "Translate", RUBY_METHOD_FUNC(gdip_matrix_translate), -1);
    rb_define_alias(cMatrix, "translate", "Translate");
    rb_define_method(cMatrix, "TransformPoints", RUBY_METHOD_FUNC(gdip_matrix_transform_points), 1);
    rb_define_alias(cMatrix, "transform_points", "TransformPoints");
    rb_define_method(cMatrix, "TransformVectors", RUBY_METHOD_FUNC(gdip_matrix_transform_vectors), 1);
    rb_define_alias(cMatrix, "transform_points", "TransformVectors");
    rb_define_alias(cMatrix, "VectorTransformPoints", "TransformVectors");
    rb_define_alias(cMatrix, "vector_transform_points", "TransformVectors");
}

redpajama_set_name: RedPajamaGithub


Winter is almost here, and we think an afternoon of some hot blues music is just the ticket to welcome it. Great live music, a vineyard tour at 2:30 p.m., exotic spiced wine drinks, wine sampling, unique gift shop, prizes & more. It all takes place at the La Belle Amie Vineyard Winter Blues Music Festival on Saturday, December 3, 2011 from 12 noon-5 p.m.
You can get in the holiday spirit with the Annual Murrells Inlet Community Christmas Parade beginning at 3:00 p.m. on Sunday, December 4, 2011. Come and enjoy the fun as the Murrells Inlet Christmas Parade starts at Wilcox Avenue (Booty's) and marches down Business 17 with marching bands, beauty queens, dogs, cycles, clowns, mini cars and more! Immediately following the parade, meet at Morse Landing Park (next to Hot Fish Club) for the Tree Lighting Ceremony. Santa Claus will visit with the children at the park. The Christmas tree will be lit and the Eagle Scouts will light a bonfire to take the nip out of the air. Christmas music will entertain the crowd at the park. Free for all! We invite friends and neighbors, businesses and clubs to join in the parade. Our number one rule is to make your entry fun for the kids! This one is all about the children. Decorate, decorate, decorate! Hand out candy! Dress up! Play or sing music! A panel of children judges will select the one winning entry in the eyes of the children! There is no entry fee to join in the parade, but we ask our parade entries to donate one unwrapped toy for the USMC Toys for Tots Drive.


text:
Home earth Hawaii Magma Tectonic
A Hole in Earth's Surface
earth, Hawaii, Magma, Tectonic 3:25 PM
Research shows that a broken lithosphere underneath the island of Hawai'i could explain the island's patterns of seismic activity.
Hawaii is one of the most seismically hazardous locations in the United States; the island has been rocked by strong earthquakes with magnitudes up to 7.9. These earthquakes occur when strain is released in the lithosphere—the Earth's crust and uppermost mantle—beneath and next to the island.
This strain is caused by the bending of the lithosphere under the enormous load of the volcanoes. As the volcanoes grow and add more weight on the lithosphere, the crust flexes downward, away from the volcanoes. The downward flexion, in turn, causes the lithosphere close to the volcanoes to flex upward. Ultimately, when the lithosphere stops flexing, the accumulated strain is released in the form of earthquakes.
In a new study, Klein proposes that the flexed lithosphere beneath Hawaii, coupled with the fact that the lithospheric plate beneath the island appears to be broken—it curves downward with a central depression—explains the region's heightened seismicity.
The resulting plate flexure forms a donut hole shape right underneath the island. The focal hole in the center lies approximately between Mauna Loa, Earth's largest active volcano, and Mauna Kea, a dormant volcano whose peak is at the highest point of Hawaii.
The author used data taken from seismic stations around the island to understand the stress fields and focal mechanisms, which describe the slip that causes earthquakes and the orientation of the fault on which those quakes occur.
The seismic data give valuable information about the orientation of the stress field and the pressure and tension axis. By analyzing the seismic data, the author saw that the pressure axis—the point where two planes compress—radiated from the center of the hole in the lithosphere. These radial patterns, according to the author, suggest that the downward-flexing lithosphere surrounds a weak region at its center.
The study was published in the Journal of Geophysical Research


text:
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Home › All Judgements › Shilpa Shetty vs. ACIT (ITAT Mumbai)
Shilpa Shetty vs. ACIT (ITAT Mumbai)
Posted on August 28, 2018 by editor — No Comments ↓
CORAM: R. C. Sharma (AM), Sandeep Gosain (JM)
SECTION(S): 92C
GENRE: Transfer Pricing
CATCH WORDS: associated enterprise, international transactions, Transfer Pricing
COUNSEL: Arvind Sonde, Haresh G. Buch
DATE: August 28, 2018 (Date of publication)
FILE: Click here to download the file in pdf format
S. 92 Transfer Pricing: (i) Chapter 10 presupposes the existence of "income" and lays down machinery provision to compute ALP of such income. S. 92 is not an independent charging section to bring in a new head of income or to charge tax on income which is otherwise not chargeable under the Act. If no income has accrued to or received by the assessee u/s 5, no notional income can be brought to tax u/s 92 of the Act (ii) It is a jurisdictional requirement that the AO has to record satisfaction that there is "income" or potential of income. The recording of 'satisfaction' about the existence of an "international transaction" is also essential. This is only within the jurisdiction of the AO and the CIT(A) cannot substitute his satisfaction for that of the AO. Such substitution of satisfaction is impermissible in law as it amounts to curing a jurisdictional defect
IN THE INCOME TAX APPELLATE TRIBUNAL "K"
BENCH, MUMBAI
BEFORE HON'BLE SH. R. C. SHARMA, AM &
HON'BLE SANDEEP GOSAIN, JM
आयकरअपीलसं./ I.T.A. No. 2445/Mum/2014
(निर्धारणवर्ा / Assessment Year: 2010-11)
Shilpa Shetty ACIT CC – 13
7/D, Aditya Apartments, SVP बिधम/ Mumbai
Nagar, Andheri(west) Vs. Pin-
Mumbai-400054
स्थायीलेखासं ./ जीआइआरसं ./ PAN/GIR No. ACPPS6622P
(अपीलाथी/Assessee) : (प्रत्यथी / Respondent)
अपीलाथीकीओरसे/ Assessee by : Shri Arvind V. Sonde & Shri Haresh G.
Buch, AR
प्रत्यथीकीओरसे/Respondentby : Shri V. Jenardhanan,
सुनवाईकीतारीख/
Date of Hearing
घोषणाकीतारीख /
Date of Pronouncement
आदे श / O R D E R
Per Sandeep Gosain, Judicial Member:
The present Appeal filed by the assessee is against the order of Ld. Commissioner of Income Tax (Appeals)-11, Mumbai, dated 30.01.14 for AY 2010-11 on the grounds mentioned herein below:-
GROUND I
1. The Commissioner of Income Tax (Appeals) – 11 ('CIT(A)') erred in confirming the action of the Assistant Commissioner of Income Tax, Central Circle-13, Mumbai ('AU') in making an addition of Rs. 3,42,85,714/- on account of transfer pricing adjustment made on the basis of Share Purchase Agreement ('SPA'/'Agreement').
2. He further erred in holding that:
a. M/s. Kuki Investments ('Kuki') was an 'Associated Enterprises" ('AE') of the Appellant within the meaning of section 92A of the Income Tax Act, 1961('the Act').
b. Mr. Raj Kundra ('RK') was a 'relative' of the Appellant within the meaning of section 92A(2)(j).
c. Appellant profession was an 'enterprise' within the meaning of section 92F(iii) of the Act separate from the Appellant being an 'enterprise'.
3. The Appellant therefore, prays that the alleged 'international transaction' was not between AE5 and therefore the addition be considered as bad in law and be deleted.
WITHOUT PREJUDICE TO GROUND I GROUND II
1. On the facts and circumstances and in law the CIT(A) erred in considering that agreeing to be associated with 'Rajasthan Royals' franchise ('RR') amounted to an "international transaction" as contemplated in section 92C of the Act.
2. He further erred in holding that the obligation to be associated with RR, free of charge, was an integral component of the consideration paid for the purchase of shares of EM Sporting Holding Limited (EMSHL') by Kuki from the existing shareholders.
3. He particularly failed to appreciate and ought to have held that:
a. the alleged services, if any, were provided by the Appellant, a resident to Jaipur IPL Cricket Private Limited ('JICPC), another resident and also the owner of the RR.
b. The Appellant becoming associated with RR was already in contemplation of parties even prior to the SPA.
c. Kuki through the SPA had already paid a sum of USD 1 million as 'Association Fee to EMSHL to purchase rights for SS to make appearances and
also be associated with RR and therefore, no benefit was accruing to Kuki.
d. If at all the Appellant promoted her image by being associated with RR.
e. It was all the shareholders that benefited from the services provided by the Appellant and not only Kuki and hence, the adjustment if any be restricted to the shareholding of Kuki in EMSHL.
4. The Appellant, therefore prays that the action of the CIT(A) in confirming the adjustment was erroneous and accordingly, liable to be deleted.
WITHOUT PREJUDICE TO GROUND I & II GROUND III
1. On the facts and circumstances and in law the CIT(A) erred in confirming the action of the AO by computing the Arm's Length Price by considering the Appellant's agreement with Hindustan Unilever Limited and applied CUP method, however, erred in taking into consideration the incorrect number of days.
2. He failed to appreciate that:
a. In terms of Schedule 2 to the SPA ('SS Obligations'), the Appellant had to be available for 10 work days (of a minimum of 8 hrs a day) to support commercial arrangements/ obligations for photo shoots, etc. b. The Appellant had to further attend all IPL matches of Rajasthan Royals (14 matches = 14 days) in addition to the aforesaid 10 days.
3. The CIT(A) / AO ought to have held that such 14 days were only for 3 working hours per day, being the actual duration of the IPL matches, which the Appellant was required to attend.
4. Accordingly, the number of days worked out by the AO and confirmed by CIT(A) is erroneous.
5. The Appellant, therefore prays that the AO be directed to recompute the transfer pricing addition accordingly.
GROUND IV The Appellant craves leave to add to, amend and/or alter all or any of the above grounds of appeal.
2. The brief facts of the case are that the assessee an individual, is resident in India and is mainly engaged in the profession of film acting and has also functioned as a brand ambassador for various products. During the period relevant to AY 2010-11 she had earned income from business and profession, capital gains and other sources. The assessee filed her return of income on 20.09.2010 declaring a total income of Rs.82,73,481.
The return was selected for scrutiny and the assessment order was passed on 31.3.2012 assessing the total income at Rs. 4,25,59,195.
The facts relevant to the addition to the returned income by the AO by way of a transfer pricing adjustment of Rs. 3,42,85,714 are that during the period under consideration the assessee was a party to a Share Purchase Agreement (SPA) signed by the existing shareholders of a Mauritius based company, namely EM Sporting Holding Limited (EMSHL) for the transfer of a portion of the shareholding of that company to M/s Kuki Investments Ltd. (incorporated in Bahamas) ("Kuki") represented by Shri Raj Kundra ("RK") and under the same SPA, Kuki was also to subscribe to additional shares to be issued by the company EMSHL. After giving effect to the SPA, the shares of the said EMSHL, Mauritius came to be held by M/s. Kuki Investments Limited, Bahamas (11.7%), Blue Water Estates Limited, Hong Kong (11.74%), Tresco International Limited, British Islands (44.15%) and Emerging Media IPL Limited, UK (32.41%). The assessee herself was neither a buyer nor a seller of shares of EMSHL in the SPA.
However, under the SPA the assessee undertook to provide brand ambassadorship services to Jaipur IPL Cricket Private Limited (JICPL), an Indian Company that was a 100% subsidiary of EMSHL, in relation to promotional activities of 'Rajasthan Royals', an IPL cricket team owned by JICPL. The SPA also provided that such services were to be provided by the assessee completely without charge or fee to the assessee or any other person.
The AO in the assessment order treated the assessee and EMSHL as Associated Enterprises (AEs) and held that the services rendered by the assessee to JICPL by virtue of the SPA involving the shareholders of EMSHL constituted an international transaction and therefore the Arms Length Price (ALP) had to be computed for such services rendered by the assessee free of charge. The AO thereafter, based on another contemporaneous brand ambassadorship agreement of the assessee with Hindustan Unilever Limited (HUL), computed an amount of Rs. 3,42,85,714 as the ALP in respect of the services provided by her free of charge to JICPL. As the assessee had not charged anything for the services provided, the entire quantum of the ALP so computed was adopted by the AO as the transfer pricing adjustment to the returned income of the assessee.
Aggrieved by such modification to the return income by the AO, the assessee filed appeal before Ld. CIT(A) and the Ld. CIT(A) considering the case of both the parties, dismissed the appeal filed by the assessee. While doing so, the Ld. CIT(A) held that the Assessee and Kuki were AEs in view of sec. 92A(1). It was also observed that the Assessee"s professional activities, which were controlled by her, constituted an 'enterprise' (distinct from Assessee herself as 'enterprise') in view of the term 'enterprise' as defined in sec. 92F(iii), thereby, held that the Assessee and Kuki were AEs in view of sec. 92A(2)(j), as RK controls Kuki and also controls the profession of assessee through assessee, RK"s relative.
Apart from that Ld. CIT(A) further applied sec. 92B(2) to hold that there was a deemed 'international transaction' between the Assessee and JICPL due to the prior agreement, i.e. SPA. Ld. CIT(A) also held that Kuki had benefitted in terms of share purchase consideration to the extent of monetary value of the (brand promotion) services provided by the Assessee to EMSHL and its the then existing shareholders on behalf of Kuki. He then made adjustment to Assessee's income on the basis of ALP.
Aggrieved by the order of Ld. CIT(A), the assessee filed the present appeal before us on the grounds mentioned herein above.
3. Since both the grounds raised by the assessee relates to challenging the order of Ld. CIT(A) in confirming the action of ACIT in making additions on account of transfer pricing adjustment made on the basis of share purchase agreement and also challenging the action of Ld. CIT(A) in considering that agreeing to be associated with "Rajasthan Royals" frenchise ("RR") amounted to an "international transaction" as contemplated in section 92C of the Act. Since, both the grounds are inter related and also challenges the jurisdiction of Ld. CIT(A) in substituting its satisfaction to that of ACIT, therefore we thought it fit to dispose of the same by this common order.
4. Ld. AR appearing on behalf of the assessee while challenging the jurisdiction of Ld. CIT(A) to substitute its satisfaction to that of ACIT(AO), submitted before us that it is a jurisdictional requirement to record a satisfaction by the AO that there was an income or potential of an income in case where the assessee had not filed the report u/s. 92E, but international transaction came to the notice of the AO. In this regard, Ld. AR relied upon i) Instruction No. 15 of 2015, dated October 16, 2015 and ii) judgment in the case of Vodafone India Services P. Ltd. v. Union of India and Others[2014] 361 ITR 531 (Born HC).
It was also submitted that the AO had recorded his satisfaction about the Assessee's potential income on the basis of AE relationship between the Assessee and EMSHL. However, the Ld. CIT(A) substituted the satisfaction by holding that the AE relationship existed between the Assessee and Kuki.
It was also submitted that recording of 'satisfaction' about the existence of an "international transaction" was only within the jurisdiction of the AO and Ld. CIT(A) could not have substituted his satisfaction for that of the AO. As per the assessee, such substitution of satisfaction is impermissible in law as the same amounts to curing a jurisdictional defect. It was submitted that if lad. CIT(A) had found that the satisfaction of the AO that an 'international transaction' exists between the Assessee and EMSHL was "erroneous" then in that eventuality, Ld. CIT(A) ought to have struck down the orders of the AO instead of substituting his reasons for that of the AO's reasons.
In this respect, assessee relied upon the following submissions/judgments /decisions:-
i.) "The AO may be confined to those reasons recorded to support his assumption of jurisdiction. "- Kanga & Palkhiwa!a's Commentary at Note 55 at Pg. 2208 of Tenth Edition of "The Law and Practice of Income Tax"
ii.) decision in the case of Hindustan Lever Ltd v. R.B. Wadkar [2004] 268 ITR 332 (Born HC) iii.) decision in the case of CIT v. Jagadhri Electric Supply & Industrial Co. [1981] 140 ITR 490 (P&H HC) iv.) decision in the case of Equitable Investment Co. (P.) Ltd. v. ITO [1988] 174 ITR 714 (Cal HC)
5. Whereas on the contrary, Ld. DR relied upon the orders passed by the revenue authorities and submitted that the Ld. CIT(A) is not an ordinary Court of appeal such as ITAT or other appellate authorities and has more powers than them. In this respect, reliance was placed upon the judgment of Narrondas Manordass vs. CIT [1957] 31 ITR 909 (Born. HC). Ld. DR also during the course of hearing relied on the decisions of Hon'ble Supreme Court in case of CIT v. McMillan & Co. [1958] 33 ITR 182 and CIT v. Nirbherarn Deluram [1997] 224 ITR 610.
6. We have heard the counsels for both the parties and we have also perused the material placed on record, judgment cited by both the parties as well as orders passed by revenue authorities. We find that although, the powers of Ld. CIT(A) being wider than that of any other appellate authorities or Court is not disputed, but the Ld. CIT(A) cannot cure a jurisdictional defect, which the AO derives only by recording a satisfaction as has been held in the case of Vodafone India Services Pvt. Ltd. Vrs. Union of India and others 920140 361 ITR 531 (Bom HC). We have gone through the decision relied upon by Ld. DR, but the para materia contained in those judgments are not applicable to the facts of the present case as the same do not deal with exercise of Ld. CIT(A)'s powers to cure jurisdictional defect. In this respect, we rely upon the decision in the case of Hindustan Lever's case (supra) and Equitable Investment's case (supra).
7. As far as objection raised by assessee on AE relationship between the Assessee and Kuki u/s. 92A of the Act is concerned, in this respect, Ld. AR submitted that Ld. CIT(A) did not uphold AO's finding that the Assessee and EMSHL were AEs. The revenue has not challenged the order of Ld. CIT(A) and consequently, the issue before us is limited to examine AE relationship between the Assessee and Kuki. In this respect, Ld. AR submitted that Sec. 92A(1) of the Act cannot be applied in isolation to hold that the assessee and Kuki were AEs. It was submitted that in order to constitute a relationship between the AEs, the parameters laid down in both sub-sections (1) and (2) of section 92A of the Act should be fulfilled.
Ld. AR also relied upon the decision in the case of Page Industries Ltd. v. DCIT [2016] 159 lTD 680 (Bang. ITAT), Obulapuram Mining Co. (P.) Ltd. v. DCIT [2016] 76 taxmann.com 240 (Bang. ITAT) and ACIT v. Veer Gems [2017] 183 TTJ 588 (Ahd. ITAT) Ld. AR on the application of Sec. 92A submitted that sec. 92A(1)(a) does not apply to the Assessee's case, as neither Kuki, through /one or more intermediaries, controls the assessee nor the Assessee, through /one or more intermediaries, controls Kuki. It was also submitted that even sec. 92A(1)(b) is also not applicable as, though RK controls Kuki, but he cannot be said to have controlled the assessee.
Ld. AR also submitted that Sec. 92A(2)(J) deems the two 'enterprises' as AEs if one of the enterprises is controlled by an individual and the other 'enterprise' is also controlled by such individual or his relatives. It was submitted in Assessee"s case, sec. 92A(2)(J) cannot be applied as neither RK nor Kuki cannot said to have controlled the Assessee.
It was also submitted that even as per sec. 92F(iii), an 'enterprise' means a 'person', engaged in activities etc. The Assessee's Profession cannot be considered as a person within the meaning of sec. 2(31), separate from her, as the Assessee's profession is not assessable separately from the Assessee. Therefore, the question of Assessee being an AE of Kuki, by holding that RK controlled Kuki and RK's relative, i.e. Assessee, controlled the 'enterprise' of assessee's profession, does not arise.
8. On the other hand, Ld. DR relied upon the orders passed by revenue authorities and submitted that assessee and Kuki were AE"s u/s. 92A(2)(J) as:
a) the Assessee's husband, RK, controlled Kuki.
b) the Assessee is an individual and as such a 'person' within the meaning of sec. 2(31).
During the course of hearing, the Ld. DR also argued that Kuki had controlled the Assessee as Kuki had paid association fee on behalf of the Assessee to EMSHL.
9. We have heard the counsels for both the parties, we find that both the above stated facts by Ld.DR, i.e. RK controlling Kuki and Assessee being a "person" u/s. 2(3 1), are not in dispute at all. The Ld. DR's submission on AE relationship between the Assessee and Kuki is based on only one limb of sec. 92A(2)(J), i.e. an individual controlled one enterprise (RK controlled Kuki). Sec. 92A(2)(J) deems the two 'enterprises' as AE if one of the enterprises is controlled by an individual and the other 'enterprise' is controlled by such individual or his relatives. The Ld. DR did not submit as to how that individual (i.e. RK) or his relative controlled the other 'enterprise' (i.e. Assessee). Without satisfying the second limb, i.e. that individual or his relative controlled the other enterprise, provisions of sec. 92A(2)(j) cannot be applied.
We have further noticed that in order to satisfy the second limb of sec. 92A(2)(J), the Ld. CIT(A) presumed that Assessee's Profession (separate from her) was the other 'enterprise' and RK"s relative, i.e. Assessee, controlled that other 'enterprise', i.e. her 'profession'. Against this presumption, it was submitted that her 'profession' cannot be separated from herself (the individual) to consider as an 'enterprise' u/s. 92F(iii) as the 'profession' (independent from individual) is not a 'person' within the meaning of sec. 2(3 1). The Ld. DR had not made any submissions against this stand taken by the assessee.
10. Now, as far as the arguments that Kuki controlled the Assessee by paying association fees is concerned, it was submitted that the association fee was nothing but earnest money which in fact got repaid to Kuki (by way of adjustment against the (consideration payable on subscription of shares to EMSHL) on share completion.
11. As far as the objection of assessee on the findings of Ld. CIT(A) on account of holding deemed "international transaction" between the Assessee and JICPL u/s. 92B of the Act is concerned, in this respect, Ld. AR submitted that Sec. 92B(2) deems a transaction between the two non-AEs as 'international transaction' if there exists a prior agreement in relation to the relevant transaction between one of the non-AE and the AE of an assessee. The Ld. CIT(A) considered the two non-AEs as the Assessee and JICPL and held a deemed "international transaction" without establishing as to with which AE of the Assessee had a prior agreement with JICPL.
It was also argued that Sec. 92B(2) of the Act cannot be applied to hold that transaction between Assessee and JICPL was an 'international transaction' as:
a) Neither any of the parties to the SPA (i.e. prior agreement) was an AE of the Assessee;
b) Nor JICPL entered into a prior agreement with the AE of the Assessee (JICPL was not a party to the SPA); and as such the pre-requisite of a prior agreement between a non-AE with the AE of an assessee is not fulfilled.
12. On the contrary, Ld. DR relied upon the orders of Ld. CIT(A).
13. After having considered the submission of both the parties, we find that Section 92B(2) of the Act cannot be applied to hold that transaction between assessee and JICPL was an "International transaction" as neither any of the parties to the SPA were an AE of the assessee nor JICPL entered into a prior agreement with the AE of the Assessee (JICPL was not a party to the SPA); and as such the pre-requisite of a prior agreement between a non-AE with the AE of an assessee is not fulfilled.
14. Now, we proceed to deal with the objection of assessee on existence of "international transaction" and "price" is concerned, Ld. AR submitted that in order to apply Chapter X, existence of a 'transaction' is a pre-requisite. It was submitted that Sec. 92C(1) makes it clear that the transfer pricing adjustment substitutes the price of the transaction with ALP. Therefore, in order to constitute a 'transaction' there has to be a certain disclosed price. It was argued that existence of an "international transaction" cannot be presumed by assigning some price to it and then deducing that since it is not an arm's length price, an "adjustment" has to be made.
15. In this respect, Ld. AR relied upon the decision in the case of Maruti Suzuki India Ltd. CIT [2016] 381 ITR 117 (Del. HC) and Bausch & Lomb Eyecare (India) (P.) Ltd v. ACIT [2016] 381 ITR 227 (Del HC) It was also argued that the word "Price" had not been defined in the Act. It seems to have been used in its ordinary sense as meaning money only. In this respect, reliance was placed on the decision in the case of CIT v. Ganesh Builders [1979] 116 ITR 911 (BomHC).
Ld. AR further submitted that in the Assessee's case, she was desirous to enhance her brand image and hence, she got associated with RR, for which Kuki had paid a deposit of USD 10,00,000/-to EMSHL as Association fee. With the conclusion of transactions of purchase and subscription of shares completing on February 13, 2009, in terms of Cl. 2.3 and Cl.5.2 of the SPA, the rights granted to the Assessee automatically terminated and the said deposit was adjusted against the consideration payable on subscription of shares to EMSHL. Therefore, the association fee was only earnest money and not monetary consideration which can be considered as 'price'.
It was argued that as the Assessee did not receive any consideration for the services rendered to JICPL, there was no 'price' which can be substituted with ALP. In the absence of any 'price', the provision of services could not be considered as an 'international transaction'. In absence of any 'international transaction', the provisions of sec. 92(1) cannot be applied and as such an adjustment on the basis of ALP cannot be made.
It was also submitted that if at all it is held that there was a 'price' and therefore there existed a 'transaction', then in that eventuality, since the services were provided to JICPL, the alleged transaction was between the Assessee and JICPL, both being residents, then in that eventuality even otherwise the alleged transaction cannot be considered as an "international transaction"
16. On the other hand, Ld. DR relied upon the orders passed by Ld. CIT(A) and also on the decision of Hon'ble Special Bench of Kolkata ITAT in case of Instrumentarium Corporation Ltd. [2016] 179 TTJ 665, to submit that, since no fee was charged by the Assessee, the price was Zero and as such the ALP has to be substituted with the same.
During the course of hearing, the Ld. DR had also relied on the decision of Hon'ble Delhi Tribunal in case of BMW India Pvt. Ltd. v. DOT [2017] ITA No. 1406/Del/2015, wherein, after considering Maruti Suzuki's case, determination of ALP was upheld. He also relied on the decision of Hon'ble Mumbai Tribunal in case of Sabre Asia Pacific Pte. Ltd. [2018] ITA No. 4882/M/2015, to submit that the Tribunal had upheld the transfer pricing adjustment on the basis of ALP determination in case of assessee advancing interest free loan to its AE, by considering the income offered as zero. After relying on these decisions, the Ld. DR contended that in Assessee's case, the price was zero and therefore, the transaction is subjected to transfer pricing adjustment based on ALP determination.
17. We have heard the counsels for both the parties and we have also perused the material placed on record, judgments relied upon and orders passed by revenue authorities, we find that none of the 3 decisions cited by the Ld. DR can be applied in Assessee's case, as the facts of the cited cases are distinguishable from that of Assessee's case as under –
i) In BMW's case (supra), BMW India had incurred expenses on marketing and promotional activities on behalf of its foreign holding company, against which it had not offered any income. It was found by the Hon'ble ITAT that the agreement between the parties provided for re-imbursement of marketing and promotional expenses by foreign holding co. and certain amount was, in fact, reimbursed to the Indian Co. Therefore, it was not a case where the price of the transaction was not disclosed and the Department had assumed certain price to substitute it with the ALP, unlike the case of the Assessee.
ii. In Instrumentarium's case, the assessee had advanced an interest free loan to its AE. The Hon'ble Special Bench observed that "consideration of loan, i.e. interest, is inherently in the nature of income ". The Tribunal, then, held that "when no income is reported in respect of an item in the nature of income, such as interest, but the substitution of transaction price by arm's length price results in an income, it can very well be brought to tax."
The transaction of services provided by the Assessee to JICPL, as against rights granted to her, cannot be equated with that of interest free loan to an AE. In Assessee's case, the deposit of money by Kuki was the price paid for shares to be issued by EMSHL. The Assessee obtained a right to appear against a reciprocal obligation to appear as and when matches were held. The deposit of money was not consideration for the right to appear.
Also, in this case the Hon'ble Special Bench did not consider Maruti Suzuki's decision (supra) and to that extent was per-incuriam.
iii. In Sabre Asia's case (supra), the counsel of the assessee had conceded the contention that the transaction of interest free loan is subjected to transfer pricing adjustments and as such the contentions raised by the Assessee before the Hon'ble Bench was not considered in that case.
18. As far as the objection of assessee with regard to the applicability of chapter 10, when no income has arisen is concerned. In this respect, the Ld. AR submitted that Chapter X pre-supposes existence of 'income' and lays down machinery provisions to compute ALP of such income, if it arises from an 'international transaction'. Sec. 92 is not an independent charging section to bring in a new head of income or to charge tax on income which is otherwise not chargeable under the Act. Accordingly, since no income had accrued to or received by the Assessee u/s. 5, no notional income can be brought to tax u/s. 92. In this regard, Ld. AR relied upon the following judgments:-
i. Dana Corporation [2010] 321 ITR 178 (AAR) – Pg. 192 & 193 ii. Amiantit International Holding Ltd [2010] 322 ITR 678 (AAR) – Pg. 682, 683 and 692 iii. Praxair Pacific Ltd [2010] 326 ITR 276 (AAR) – Pg. 279 and 286 iv. Deere & Co [2011] 337 ITR 277 (AAR) – Pg. 280 & 284 v. Venenburg Group B.V [2007] 289 ITR 464 (AAR) – Para 15 at Pg. 472 vi. Goodyear Tire & Rubber Co. [2011] 334 ITR 69 (AAR) – Para 10 at Pg. 78 vii. Vodafone India Services (P.) Ltd. v. Union of India [2013] 361 ITR 531 (Born HC) – Para 32 at Pg.
viii. Vodafone India Services (P.) Ltd. v. Union of India [2014] 368 ITR 1 (Born HC) – Para 24 (Pg. 30), 40 (Pg. 37-38) ix. Vodafone India Services (P.) Ltd. v. Union of India [2015] 369 ITR 511 (Born HC) – Para 8 at Pg.
x. Vodafone India Services (P.) Ltd. v. CIT [2016] 385 ITR 169 (Born HC) – Pg. 312 and 320 The Ld. AR further submitted that when the machinery provisions fail, then the charging provisions cannot be applied. In this respect, Ld. AR relied upon the decision in the case of CIT v. B.C. Srinivasa Setty [1981] 128 ITR 294 (SC) and CIT v. Official Liquidator, Palai Central Bank Ltd. [1979] 117 ITR 676 (Ker. HC)
19. On the other hand, Ld. DR relied upon the orders passed by revenue authorities and the decision in the case of Instrumentarium's case (supra) to contend that the price was zero and the provisions of Chapter X would apply accordingly.
20. After hearing both the parties at length, we find that since we have already rebutted the Ld. DR"s reliance on Instrumentarium's case above in detail, therefore the same are not applicable to the facts of the present case and we are of the view that since chapter 10 pre-supposes the existence of "income" and lays down machinery provison to compute ALP of such income, if it arises from an "International transaction". Section 92 is not an independent charging section to bring in a new head of income or to charge tax on income which is otherwise not chargeable under the Act. Accordingly, since no income had accrued to or received by the assessee u/s 5, no notional income can be brought to tax u/s 92 of the Act.
We draw strength from the following judgments in the case of :-
x. Vodafone India Services (P.) Ltd. v. CIT [2016] 385 ITR 169 (Born HC) – Pg. 312 and 320 And keeping in view of our above finding, we allow these grounds and direct the AO to deleted the additions.
21. Since we have already deleted the additions by above reasoned order, therefore there is no need to adjudicate other grounds on merits in view of our above findings as the same become infructous.
22. In the net result, the appeal filed by the assessee stands allowed.
Order pronounced in the open court on 21st August, 2018.
Sd/- Sd/-
(R. C. Sharma) (Sandeep Gosain)
ले खासदस्य / Accountant Member न्याययकसदस्य / Judicial Member
मुंबई Mumbai;यदनां कDated : 21.08.2018
‹ CIT vs. Classic Binding Industries (Supreme Court)
Muninaga Reddy vs. ACIT (Karnataka High Court) ›


This summer I presented at a conference at York University where we discussed what it could mean to be posthuman in the context of international relations, and specifically for security studies. How can we define the posthuman? How would we know if we are posthuman? How about if we were never human (Haraway) or never modern (Latour)?
In my work, I write about the more than human; how human bodies, with their many messmates and commensals, can be used to think about politics in a complex, interrelated world. The pure human doesn't exist and never did. In my side projects and teaching, I like to think about the human and technology. Cyborgs, robots, enhancements, medical technology. I focus on the drawing of the line between who we see as human and who doesn't make the cut: when do we become nonhuman/posthuman/superhuman in this context? If we have a pig valve in our hearts? Cheetah legs for running? Exosuits for battle? Laser eye surgery? Performance enhancing drugs?
So, for fun I thought I might ask this question: Rather than biologically or technologically, how could we define a quantum posthuman? Metaphorically speaking. There are many new ideas in physics explaining quantum mysteries, new formulations on the behavior of light, and explanations for quantum entanglement, or spooky action at distance. If they aren't making your mind explode, you ain't reading 'em right. What does thinking about bodies at the quantum level do for us up here?
Last month, The New Scientist featured an a new approach to quantum mechanics that explores quantum weirdness as a "sign of many ordinary but invisible universes jostling to share the same space as ours" rather than the early many worlds interpretation of quantum mechanics in which the universe splits into pairs of parallel universes when a wave function collapses. In early interpretations, this means Schrödinger's cat is both dead and alive depending on the universe in which you find yourself. The worlds do not interact.
In this new theory, argued by Howard Wiseman, at Griffith University in Australia, parallel worlds have always existed, and these universes interact by bumping or colliding into each other. This means the number of worlds would be finite and, with careful experiments, scientists could figure out how many worlds there are in total. And, amazingly, this raises the possibility that we could communicate with other worlds—and our twins that live there. Schrödinger's cats could meet or go to each other's funerals, I suppose. If there are multiple humans, occupying the same space, experiencing different lives, this seems to take questions of human subjectivity and individuality away from the traditional monist v. dualist debate. Our division between self and other breaks down—we are multiple versions of ourselves, unique but sharing the same space-time. We are always already Othered. Future theories of the human, (the posthuman?) would have to leave behind much of the current thinking that rests on the human as an individual. Like the sculpture above, Quantum Man, what if we are slices, or smears on a universal map of sorts?
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I don't really see how adding these layers/complexities really change any of our lived senses of ourselves and more importantly for politics how we make our decisions. We really aren't adding any new voices to the process (who will speak for the trees and how?) and at least in the US more diversity in government has added more tensions and resulted in more gridlock, no?
As we already can't handle the limited complexities we generally deal in/with how does adding more help?
OHHHHH, the "so what" comment (a personal favorite for me too). I wonder about that sort of thing all the time when I am reading Haraway — so what? The comment "we have never been not cyborgs" or "we have never been modern" both strike, at first, a super critical note, but then moments later the gravity seems to lessen and one solution is "if we have never been not cyborgs, then being cyborgs is a universal thing, and therefore nothing particularly unique or interesting." I am not sure I am willing to take that line of thinking to its logical conclusion; however, I can see the position being appealing to many.
for me (not surprisingly) the point of emphasis is not on the abstractions but on what people are actually doing (and or are capable of doing), easy to manufacture all sorts of imagined imperatives with catchy names not so easy to assemble truly new ways of doings things off the page.
For example academics regularly change the vocabularies (and occasionally/generationally the people representing differing related categories) they salute while leaving the organization of their depts/schools largely untouched.
A world without the "Human" was not really an option for me until recently in my academic career. Perhaps unknowingly in the past I was exposed to all manner of nonhuman agency (interest in ghost machines or machines taken-over by ghosts), fictional depictions of human/alien hybrids (as part of my love of sci-fi and fantasy novels), and a young obsession with human appendage augmentation (for example, I was really too interested in Schumann's "finger strengthening device" used to make him a better pianist [even though now, looking back, I think he really only had advanced syphilis]). The only difference is — we didn't call any of it posthuman even though perhaps some of it was.
Here is a small beef I have and I'd appreciate some dialog on it. Part of what made those sorts of posthuman themes so interesting was likely exactly that the "Human" was so firmly entrenched in my/our thinking. So, what makes the posthuman interesting in a world without a stable sense of the human or individual? What I mean by that it is, what is the posthuman a viable alternative to if the human is not at least a little bit convincing. As Bartelson once said about state rejectionists (i.e., scholars that say "the state does not exist!"), having a critical theory of the state is somewhat akin to having a critical theory of unicorns or leprechauns — if the object of study is so unbelievable, critically rejecting it becomes intellectual horseplay at best. How does the posthuman dynamic makes sense of that?
Part of what I am gesturing to in the first paragraph is about this very beef, Nick. Ultimately, I am not sure thinking about the "posthuman" as a category does much good methodologically. I talk about the more than human in that I do a assume something human and add to it. We decided at the workshop that it wasn't really that useful. I think the interesting bit for me is what happens when we take away humanhood. The post human is a good foil for seeing what happens when people are seen as less/more than human in politics. I am trying to think it through in the sense that we have never been posthuman, I guess. I think our third blogger will push this further.
Okay, "more" or "less" human is an interesting case for boundary work with some possible real-world applications too (lots of these divides in sociology over the last century — deserving versus the undeserving poor, for example).
Also, this is just a side note: when you say "gesturing" in your response, what does that mean? I'm not trying to be a Socratic ninny on on this one, but what makes a gesture in this context a gesture rather than something else? Just curious.
dmf, I respectfully disagree–I think our very gridlock in US politics is that we don't have enough diversity/plurality. Many voices can't be heard institutionally (Tweedism is a big problem as well as corporate ownership of our Congress and Senate. What point is there in voting in an oligarchy where elite voices are the only ones heard? http://www.bbc.com/news/blogs-echochambers-27074746). There are people who literally can't breathe in America, and the rest can't see or empathize.
are you saying that the people representing us in government (and the people able to vote for them) isn't more diverse than it was after WW2?
even if we put that aside I think it doesn't really address the how questions I raised, how do we add to the mix and how would it/we really be different from what we do now other than more data to potentially be processed?
For my work, the posthuman is wrapped up in my ideas on the environment. It isn't adding categories, but rather changing them that makes the difference. Dolphins rather than BP. I guess that I think if we can change the way we think about ourselves as humans (the green movement needs an affect that is different than "tree hugging"). We also can't use "ecology" as a new opiate of the masses (Zizek says this well in the movie Examine Life) but rather as a way to not see the earth as only use value.
ok but how does "changing them that makes the difference" this actually work?
what would be an example of success?


Seeing as Sams is owned by the same company as Walmart I'm surprised that they close on Thanksgiving, Easter, and New Years.
Good info. But Sams club should be closed for morhers day. Knowing half the employees are morhers. Should be a day for them to rest an be respected.
Kingston Sams club does not stay open until 10pm for its plus members.


Lupe has been working with Paul Bancroft Roofing Inc. since 2001. She takes pride in providing exceptional customer service to each and every client. Many of our clients see her as the 'go to' if there are any questions that they may have. Lupe graduated with a Bachelors of Science from CSUN and has worked in the administrative field for fortune 500 company Black & Decker and in sales with Fireman Fund.
Lupe enjoys spending time with her family creating arts and crafts.


text:
How To Reduce Loan By 10yrs
Home/How To Reduce Loan By 10yrs
Analysis by leading comparison website Canstar has found a typical borrower can shave between 10 and 16 years off their mortgage by refinancing to a lower rate, using an offset account and making extra contributions.
It found for a typical $500,000 30-year home loan:
• Switching from an average variable rate of 3.14% to a low rate of 1.89% one year into the mortgage could save $139,000 in interest plus five years and four months of time.
• Paying an extra $200 a month into the mortgage could knock three years and nine months of a mortgage's life, plus cut $37,000 of interest.
• Keeping $20,000 sitting in an offset could save $28,000 of interest and wipe one year and one month off the loan term.
More than 16 years could be cut off the mortgage if borrowers make bigger extra contributions each month of $500 and hold $50,000 in an offset account, Canstar found.
"Repaying your home loan early can clear both your head space and budget capacity for starting a serious wealth creation push and doesn't have to come with a lot of pain," says Canstar group executive financial services Steve Mickenbecker.
YSV2021-11-03T05:18:07+00:00November 3rd, 2021|


Grapes can be used for more than just wine. Try them in tarts, wine jelly or added to sauces. Cut them into little bunches and serve with cheese, or add to fruit salads. Discover new ways to use grapes in your cooking with our delicious recipes below.


Hi everybody my name is Sophie Yarosh! My best and only friend is my grandma, oh and she's also my lover. You can find me in the bathroom because I'm always pooping, but if I'm not there I'm probably on the phone with my mom. She's my third best friend. Hit my line if you want to talk about bodily functions, being stressed out or how to not take accidental three hour naps. My catchphrases include, "boi what are thooooose," "does my outfit look okay," and "my mom is so mad at me because I didn't clean my room." Oh also I'm a Copy Editor.


text:
Home » Foreign » Iran arrests suspects in 'unforgivable' plane disaster as protests persist
Iran arrests suspects in 'unforgivable' plane disaster as protests persist
On January 14, 2020 10:35 pmIn Foreignby Temisan Amoye
Iran said on Tuesday it had arrested people accused of a role in shooting down a Ukrainian airliner and had also detained 30 people involved in protests that have swept the nation for four days since the military belatedly admitted its error.
Wednesday's shooting down of Ukraine International Airlines flight 752, killing all 176 people aboard, has led to one of the biggest public challenges to the Islamic Republic's clerical rulers since they took power four decades ago.
President Hassan Rouhani promised a thorough investigation into the "unforgivable error" of shooting down the plane, in an address on
ALSO READ: Police arrest suspected killers of Lagos worker, Moradeun Balogun
Britain, France, and Germany also increased diplomatic pressure on Iran, launching a dispute mechanism to challenge Tehran for breaching limits on its nuclear program under an agreement that Washington abandoned in 2018.
Tehran has faced an escalating confrontation with the West and a wave of unrest since the United States killed Iran's most powerful military commander in a drone strike on Jan. 3.
Iran shot down the plane on Wednesday when its military was on high alert, hours after firing missiles at U.S. targets in Iraq. It admitted the mistake on Saturday after days of denials.
Judiciary spokesman Gholamhossein Esmaili said some of those accused of having a role in the plane disaster had been arrested, although he did not say how many or identify them.
ALSO READ: Man dies in Edo hotel swimming pool
Since the official admission, protesters, many of them students, have held daily demonstrations, chanting "Clerics get lost!" and calling for the removal of Supreme Leader Ayatollah Ali Khamenei, in power for more than 30 years.
Police have responded to some protests with a violent crackdown, video posts on social media showed, with police beating protesters with batons, wounded people being carried, pools of blood on the streets and the sound of gunfire.
A video to emerge on Tuesday showed an officer using an electric baton to shock a man as he writhed on the ground.
Iran's police have denied firing at protesters and said officers were ordered to act with restraint. The judiciary said 30 people had been detained in the unrest but said the authorities would show tolerance toward "legal protests".
Temisan Amoye
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Askia presents groundnut seedlings to female farmers in Uzere
Abiodun felicitates with Uzodinma


Despite living only 30 minutes away from Toronto, Adam and I often take for granted how much there is to do and see in our city. You may have read about our weekend in the city here, but I didn't get to share too many details about our staycation at the Ritz-Carlton Toronto.
Nestled in the heart of the Entertainment District, this property is definitely a must see if you're new to the city or a local looking to book a weekend getaway. With many theatres nearby, King St. restaurants a block away and the Rogers Centre a stone's throw away, you couldn't pick a better location to get yourself acquainted with the best the city has to offer.
The best Peruvian food in the city!
After a scrumptious lunch, we headed upstairs to get a sneak peek at our digs for the next two nights. Immediately upon walking in you couldn't help but notice the floor to ceiling windows of the CN tower, which were absolutely breathtaking. It then dawned on me how incredibly spacious the room was – yes, even for the incredibly large suitcase I packed for just two nights! – and surprise, surprise… the Ritz-CarltonToronto actually hosts some of the biggest guest rooms of any hotel in the city.
Moving on to the bathroom – an oversized soaker tub, marble accents throughout and an HD TV placed behind the vanity mirror. Let me tell you – getting to catch up on the Real Housewives of New York City and doing your makeup is a dream come true!
Always love the fresh flower displays in the lobby!
As if we weren't feeling pampered enough, I had the privilege of getting to visit the Spa My Blend by Clarins for a personalized treatment. There's only two of these spas in the world - Paris and Toronto – so to have the opportunity to visit was beyond my expectations. I was lucky enough to try the My Blend Facial treatment from the spa. I loved getting to have a personalize consultation with my skin coach so she could find out more about my skincare regime, skin type and more. And for those interested in knowing? Yes, it was the most amazing facial of my life. I actually snapped some brave before and after photos on Instagram stories because I was so impressed with the results.
Following my facial, I was led to the infamous Relaxation Room. Ask any Torontonian about their favourite spa in the city and they'll rave about the Ritz-Carlton Toronto and this space. With soaring ceilings, artistic details and a private lounge area, it completely wraps up an already amazing experience on such a positive note.
Feeling rejuvenated from my spa treatment and with a few hours to spare before dinner, we walked around the local area and wound up at Ripley's Aquarium for the first stop on date night. The jellyfish are a must see! For dinner, we dined on site at TOCA restaurant. I must admit, I had heard great things about this spot for years but never quite made it with such an influx of new spots in the Toronto scene. Consider yourself warned: you must be sure to get there as soon as possible.
An Italian themed restaurant tucked on the second floor of the hotel, it's one of the best kept secrets in the city. We sampled their Canadian inspired menu which is not to be missed. With a wine paring per course and the best lobster pasta we've had – it's definitely worth a visit. And try to score yourself a visit to the Cheese Cave while you're there.
Sunday morning was a slow start for us strolling around the city visiting one of our favourite spots for brunch and hanging around the King West area. We made our way back to the Ritz Carlton for a quick dip and laid low for the day soaking up the fact that we were tourists in the city. We moved the party outside to enjoy drinks on DEQ – the patio bar located on site at Ritz Carlton. With a Blue Jay's game recently wrapping, the energy was insane and the views of the CN Tower are priceless.
Love that they have a candy bar in the lobby!
We wrapped our day with more city exploring and headed to the Ossington neighborhood for a quick bite and sweet treats and then to Bloor St. in Yorkville for some shopping. It was only 2 days in the city but it felt like we had taken a mini vacation in a city that we only ever get to experience in short segments here and there. We had such a fabulous stay and I would certainly recommend the property if you're visiting Toronto for the first time or if you're also looking for a fun escape to this fabulous city we call home.
And don't forget - you can score an Epic Canadian adventure all your own with Marriott properties. Enter here to snag a vacation for you and a friend to a destination of your choice across the country!
This post was sponsored by the Ritz-Carlton Toronto. All thoughts and opinions expressed are my own.
I love that dress! It's always so refreshing to go out and explore your own city!
I've had it for over a year now and can't stop wearing it!
Haha I can't argue with you there!
Love the lace overlay dress!
Lovely photos! That laced dress looks fantastic on you!
I love the dress so much; this looks LOVELY!!! I can just feel the relaxation. What was in the drink with the ball in it?! Some kind of spherical amazing icecube? Looks delish.
Oh my goodness! What a treat! I'm heading to the Ritz Sarasota Florida in about a month. The hotel is divine, the people are super nice, and the pool club is fantastic! Can't wait!
p.s. Staycations are such a great idea! I've done the same here in Waterloo, and I always feel like I've been on a vacation!


text:
function vpn {

  STATUS=$(systemctl list-units | grep openvpn@)

  CMD=${1:-status}

  case "$CMD" in
      off)
          if [ -z "$STATUS" ]; then
              echo "No vpn active"
          else
              PROFILE="${STATUS%.*}"
              echo "Stopping $PROFILE profile"
              sudo systemctl stop $PROFILE
          fi
          ;;
      status)
          if [ -z "$STATUS" ]; then
              echo "Status: off"
          else
              echo "Status: $STATUS"
          fi
          ;;
      help)
          echo "Usage: $0 [help|status|on|off|PROFILE]"
          ;;
      on | *)
          PROFILE="$CMD"
          if [ "$PROFILE" = "on" ]; then
              PROFILE="de"
          fi

          if [ ! -f "/etc/openvpn/$PROFILE.conf" ]; then
            echo "Unknown vpn profile"
            return 1
          fi

          if [ -n "$STATUS" ]; then
              PROFILE_OLD="${STATUS%.*}"
              echo "Stopping $PROFILE_OLD profile"
              sudo systemctl stop $PROFILE_OLD
          fi
          echo "Try to start profile openvpn@$PROFILE"
          sudo systemctl start openvpn@$PROFILE
          ;;
  esac
}

function _vpn {
  local cur=${COMP_WORDS[COMP_CWORD]}
  local vpns="$(/bin/ls /etc/openvpn | grep '.conf' | cut -d. -f1) on off status"
  COMPREPLY=($(compgen -W "$vpns" -- $cur))
  return 0
}

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20% of the proceeds from this bracelet are donated to BCRF.
The Breast Cancer Research Foundation (BCRF) is a not-for-profit organization whose mission is to achieve prevention and a cure for breast cancer in our lifetime by providing critical funding for innovative clinical and translational research, and increasing public awareness about breast health. In 2009 about 192,370 new cases of invasive breast cancer will be diagnosed among women in the United States. At this time there are about 2.5 million breast cancer survivors in the United States. In 2009, ACS estimates that about 40,170 women will die from breast cancer in the United States. Breast cancer is the second leading cause of cancer death in women, exceeded only by lung cancer.
Since its inception, the Foundation has raised over $237 million to support clinical and translational research at medical institutions across the globe conducting the most advanced and promising breast cancer research that will help lead to prevention and a cure in our lifetime. BCRF is recognized by AIP as one of the "Top Rated" cancer organizations, and is the only breast cancer organization to appear on its "Top Rated Charities". The Foundation depends on contributions from all those concerned with women's health. Working together, we know we can find a cure in our lifetime.


Distance between Sturgis and Rouleau. How many miles from Sturgis to Rouleau.
The straight distance between Sturgis (Saskatchewan) and Rouleau (Saskatchewan) is 158.64 mi, but the driving distance is 201.29 mi.
It takes 3 hours 35 mins to go from Sturgis to Rouleau.


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#MenToo
Posted on November 20, 2017 byJosh Bullen
It is 28 days since actress Alyssa Milano's infamous tweet that sparked a social media debate about men's behaviour towards women and globally engendered power imbalances. The #MeToo campaign has since been attributed to Tarana Burke's 2006 grassroots campaign on MySpace, which was aimed at creating 'empowerment through empathy', particularly among women of colour from underprivileged communities. #MeToo is no doubt very different to what Burke envisaged in 2006, with less of a focus on race and privilege and more concern with sexual harassment and assault. Her campaign dealt with a different but no less important form of discrimination, however without major celebrity support failed to gain the same level of public attention as the more recent #MeToo.
The conversation about sexual harassment in its current online form goes back much further than the #MeToo campaign. After all, #MeToo came about on the anniversary of the 2005 Access Hollywood tape in which US president Donald Trump bragged "when you're a star, they let you do it". The response to Trump's misogynistic comments in 2005 was similar to that of the recent Harvey Weinstein revelations and resulted in the #NotOkay campaign.
So, what has changed between #NotOkay and #MeToo? First, the effects of #MeToo have been visible, not only in the ramifications for Harvey Weinstein but for a number of other men. Sam Kriss, a journalist for Vice, Rupert Myers, political correspondent for Vox Media and Lockhart Steele, editorial director at Vox Media were all fired after sexual harassment and sexual assault allegations came to light as a result of the campaign. Perhaps actions do have consequences after all.
Second and perhaps most encouraging is #MeToo's male representation, response, and engagement. A factor mentioned in many articles discussing the campaign is the detached representation of men as supporters. This is not to deny that the majority of sexual harassment and sexual assault cases are perpetrated by men and suffered by women. Neither is it to shift the focus of the campaign away from empowering women to become more vocal. But if the purpose of the conversation is to truly change some men's behaviour, then we need to enter into a meaningful dialogue with them, by acknowledging, involving and challenging them to discuss.
I will be the first to admit that it is very difficult, as a man, to accept there will be men I know who have committed acts of sexual harassment or even sexual assault. Although they are not representative of all men, there is more we can do as men to challenge these aggressors and stand with women. And there are men that have done just that. Benjamin Law, an Australian journalist, and screenwriter responded by taking to Twitter and create a brothering hashtag to #MeToo entitled #HowIWillChange.
Not all reaction to the #HowIWillChange hashtag was positive, however. While a number of men began to tweet how they would change their behaviour in support of #MeToo, others saw this new hashtag as an attack on their personal characters and values. They began tweeting responses:
"#HowIWillChange – I Won't. I'm not a bad guy. I won't be forced to feel like one."
I can't help feeling that these men are involving themselves in a campaign they do not fully understand.
They are not the only misguided commentators within this discussion. Margaret Wente, a columnist for Canadian newspaper The Globe and Mail, among other simplistic comments wrote "The vast majority of men are not violent sexual abusers… and to sort of tar the whole male gender with this problem is very unfair to men". There have been many responses to #MeToo, but it is difficult to evidence an indiscriminate tarring of the male gender. If men feel similar to those referred to above, that they are scrutinised under the same behavioural microscope as women are daily, then I say good. Empathy is an important lesson.
While it is optimistic to think that the #MeToo campaign can change an entire oppressive system, what it has provided – for me at least – is insight into the scale and frequency of the oppression women face daily through stories from women in my life. What the campaign hasn't done is reveal the full extent of the problem. I'm well aware that there will be many women out there, probably some of whom I know well, who didn't take part in the campaign for various personal reasons. But what they should know is that should they choose to speak, they won't be alone. It isn't their fault. It's the man's fault. And if they stand up to him, I and other men like me will stand with them.
Josh Bullen
Blog, Gender Equality, Human Rights, Media, North America, Politics, Society, The DiA Blog, Trump