Sometimes, the hardest part of risk management is identifying the areas of weakness within your environment. I would argue, however, that more often than not, the more difficult undertaking is deciding how to address said weaknesses.
This is often done by consulting with an expert in the organization or researching industry best practices. Or–if you're more interested in an objective, rigorous, and statistical backed method–by conducting quantitative risk analyses to aid in the calculation of ROI for each of the potential solutions.
The risk associated with a non-malicious insider (Threat) misaddressing emails containing sensitive customer information (Asset), resulting in confidentiality loss (Effect).
The number of unique records contained per email was between 1 – 250.
After conducting the current state analysis, we then did multiple future state analyses to assess each of the control alternatives. In order to do so, we considered the impact each of the controls would have on the FAIR model and made the related changes to the analyses.
Email notification was the first control considered as it would pose little to no additional cost to the organization. This would be a pop-up notification triggered by the email provider when PII was detected. It would instruct the sender to double check the recipient and attachments prior to sending. Given that this control notifies the sender prior to the email being sent, it reduces the Threat Event Frequency (or number of times per year a misaddressed email containing sensitive information is sent).
Given it reduces the likelihood of sent misaddressed emails reaching the recipient, it will reduce the Vulnerability component.
Additionally, given that it effectively caps the total number of records that can be sent, it also reduces the record count and thus reduces the loss magnitude.
The final control considered was less technical and more operational in nature. The organization was considering implementing periodic employee training workshops in order to increase awareness and caution in sending sensitive information. Given this impacts the likelihood of misaddressed emails being sent, it was modeled at Threat Event Frequency.
Based on the results of the analyses, it was determined that implementing DLP block would result in the greatest risk reduction of the control alternatives, $108,000. However, email notification also showed a significant reduction in loss exposure at $64,000 and required little to no investment.
Given the risk reduction, cost, and understanding of productivity implications, the organization was able to determine which alternative would offer the best return on security investment.


This weekly, interactive program includes a variety of activities. Every week enjoy books and fingerplays. Many weeks you'll find a little extra sparkle, with fun additions such as puppets, creative movement, play activities, or sometimes even a short film.
Families with children of all ages are welcome, but children ages 18 months – 6 years old will enjoy it best.


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Skip X Games? For most athletes, not a chance
Austin Colbert
acolbert@aspentimes.com
Athletes invited to the Aspen X Games opening press conference held at Buttermilk Mountain on Wednesday afternoon.
Anna Stonehouse/The Aspen Times |
It's a fair question during an Olympic season and one the athletes get quite a bit: Are you going to compete in X Games?
While there have been instances where an athlete will skip the annual event in Aspen to focus on the Olympics — halfpipe snowboarder Shaun White opted out of the 2014 Winter X Games to train for the Sochi Games — the resounding answer from many of the athletes during Wednesday's introductory news conference was "absolutely."
"I just think it's a really good gauge of what you are going to see at the Olympics," Canadian snowboarder Mark McMorris said. "There is really no point in not doing this event. You want to sharpen your competitive skills."
The 2018 Winter Olympics in South Korea officially gets underway Feb. 9, making this week's Winter X Games the final significant event ahead of the big show. While skipping the ESPN showcase in Aspen crossed many minds, it seems nobody followed through on it.
The notable absences, such as Estonian skier Kelly Sildaru and Tahoe snowboarder Danny Davis, are injury-related. The who's who of the sports are here and ready to compete, including White.
"This is where our sport was born and came into its own. It's really special for us," said Tahoe skier Maddie Bowman, who won Thursday night's women's ski halfpipe final. "This is a pretty unique spot where you really do get to show the best of the best. The riding is always at an insane level and the energy is always so amazing."
American halfpipe skier David Wise, the reigning Olympic gold medalist who won Thursday night's men's ski halfpipe final, believes most people would skip X Games out of fear of getting hurt, a valid reason considering the Winter Olympics only come around every four years.
However, that's never been his style.
"Taking the momentum from X Games into the Olympics has always been my strategy," Wise said. "Yeah, we are going into the Olympics very soon. We are within a month from finals of my event, and it would be maybe in some people's minds to skip X Games, stay healthy. But at the same time you can't live your life in fear of injury. We are at the highest level of our sport. We are at the cutting edge. We have to go in expecting to land runs."

redpajama_set_name: RedPajamaCommonCrawl


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The wait is over, and the vacation season is finally here. There is no higher time of the yr to celebrate with own family and to change items. Suppose you are like us. You then realize that finding the right gift for your loved ones can be a chunk of challenging. Especially in case you're loved ones love technology. Every yr is a bit distinct, with new gadgets popping out, and it's miles tough to hold the tune of which ones are present day. We are here to help make your lifestyles clean and provide you with the top 10 devices for 12 months.
1. Apple iPhone 5
2. Apple iPad Mini
3. Nintendo Wii U
Why need to I get a Nintendo Wii U?
4. Amazon Kindle Fire HD
5. Samsung Galaxy Note II
The Apple iPhone 5 is right here, and it has accomplished thoroughly as expected. The iPhone 5 has been offered out at several stores, and there were lines of people ready at stores to be the primary to get their fingers on the coveted iPhone five. A lot of people are in a settlement that the lengthy wait changed into well well worth it. There have been a few mishaps, controversies, and departures of excessive-level executives forced to leave the corporation. One factor for certain is that Apple usually creates lots of buzzes and a whole lot of income. The Apple iPhone five is the most powerful and most powerful of all the iPhones previously. The iPhone 5 is powered by the A6 chip making it nearly two times greater efficient than the iPhone 4. The tool can be capable of manage multiple tasking with plenty of greater ease. The iPhone five will have the familiar Siri because the trusty assistant supplies voice automatic responses when needed.
The iPhone five is one of the quality equipment to use when you take snapshots because it comes with an 8-megapixel digicam. This may be one of the maximum vital capabilities of the iPhone is taking pictures and making motion pictures of your own family. The iPhone has, in reality, developed into a completely effective product that has taken the USA via typhoon. We continue to count on sturdy income from Apple. There can be three models to pick out from the sixteen GB, 32 GB, and 64 GB. You could be able to choose from special colors: white or black. There are such a lot of packages to pick from, with over 250,000 and counting. The Apple iPhone five remains the most powerful product inside the marketplace, using a long way with very little competition from absolutely everyone.
Apple has been below numerous strain by stakeholders to launch a pill that would compete with organizations like Amazon and Google for market share within the decrease quit pill market that makes it less difficult for human beings to enter into the pill market and become customers of any such businesses where they can buy their software from. One of the most important market tendencies is that each of the important tablet producers is liberating low-give up and excessive-quit capsules to cater to all markets. Apple isn't any different, and the super news is that Apple has achieved it once more with today's launch of the Apple iPad Mini to fight off the opposition from the Google Nexus 7 and Amazon Kindle Fire HD drugs. Their competition had been ingesting far away from Apple's sales by presenting merchandise at lower fees and lesser hardware capabilities. There has been a primary market for cheaper tablets, and now, with the discharge of the iPad Mini, Apple is trying to hold directly to it is thrown because of the king of the pill market. The iPad Mini is a prime shift inside the corporation's strategic direction in which they had been seeking to simplest make excessive-end pills. The stress from their competition and their need to satisfy the demands in their stockholders become an interesting alternate of their strategy and a completely welcomed reaction via the public. The iPad Mini boasts some serious specifications:
We count that the iPad Mini will make several sales on commencing day and that Apple will preserve to guide towards Amazon, Google, and Microsoft. The iPad Mini will strengthen the employer's product portfolio and construct an already strong patron base. The iPad Mini can be small; however, to traders, this will be very massive.
The international has been watching for months to release the Nintendo Wii U, and the system is finally here! The Wii U is the following era online game gadget that Nintendo has launched because Nintendo Wii got here out 1/2 a decade in the past and made document income. Nintendo has quite a few expectancies to live up and is beneath a whole lot of strain to make certain that their state-of-the-art device is a success. Nintendo has had important trouble with the Nintendo 3DS earlier than they were given the system lower back on course. We agree that the Nintendo Wii U is a machine positioned at an appealing fee point and could upload price to purchasers.
The Nintendo Wii U has the nice video game developer inside the records within the industry backing up the machine a hundred%, which is none apart from Nintendo. There isn't any different gadget in which you can play Mario, Luigi, Zelda, and Kirby to call some exceptional characters from the Nintendo universe. This is why you want to get a Nintendo Wii U due to the Nintendo games. The big game that humans have become this holiday season after they get their Nintendo Wii U is Super Mario Bros U. This is the subsequent new release within the Super Mario Brothers recreation that changed into a huge side-scrolling fulfillment. The game looks like several fun, and it has your favorite character staring in the game, Mario.
Amazon has evolved one of the fine ecosystems over the net that allows their clients to move films, study books, pay attention to music, play video games, buy groceries, and do a whole lot more. The people who might be clients of Amazon are really huge fans in their offerings and are unswerving to the company. Amazon commenced as simply a web ebook keep and has grown into one of the main technology companies within the international. They came out with the Amazon Kindle as an e-reader to examine books that have become very prevalent inside the market. In fact, it became the top-selling e-reader within the enterprise. Later, Amazon released the Amazon Kindle Fire HD as an opportunity for humans that couldn't come up with the money for an iPad, and it did pretty well. Now, they have finally evolved a product worthy of delivering their content over hardware that their lovers are surely going to love. So, Amazon fans, the wait is eventually over; the new Kindle Fire HD is right here!
The Amazon Kindle Fire HD leverages a completely sleek, black design. This is very easy to examine and is comfy to preserve, which is a major step far from the cumbersome model of the preceding design of the authentic Kindle Fire. Amazon desired to deal with the whole market to evolve two extraordinary models with two awesome fee fashions.
There is no other form element inside the marketplace. This is equivalent to the Samsung Galaxy Note II. Is it a mobile smartphone? Is it a pill? Whatever you want to call it, this hybrid is particular, dynamic, and really popular with consumers. There is no different technology within the marketplace that absolutely makes us this excited about the exceptional styles of matters that you could do with just one cellular tool. You can take notes, watch films, take photos, play video games, take a look at your emails, and make smartphone calls.
The Samsung Galaxy Note II is constructed off of the award triumphing Google Android working gadget that capabilities the four.1 Jelly Bean that everybody has been speaking about for a totally long term. The working device is extraordinary fast that is supported by a ton of programs. The display screen is one of the most mentioned functions on the internet. The device has a high definition 5. Five-inch display screen! The cellphone is likewise loaded with 16 gigabytes of memory to keep all of your music and your snapshots. The tool comes with two cameras, with the one within the smartphone's back; an 8-megapixel digital camera lens powers this.
One of the unique matters about the Samsung Galaxy Note II because the name indicates is that it comes with the S Pen, which reminds us of a piece of the Nintendo DS. The S Pen is a stylus that you could use on your phone screen to take notes of approximately anything you like. The Samsung Galaxy Note II is one of the few instances that we will say is a sequel well worth searching into.
Kitchen Equipment And Gadgets For Your Raw Food Kitchen


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Monkeys, Apes
New Content From Current Directions in Psychological Science
A sample of articles on brain and learning, handedness in primates, cognitive modeling and large-scale digital data, language, blame, credibility in psychological science, musical synchrony, innovations in clinical science and assessment.
Much More Online
Featuring articles on neuroscience, podcasting, and military veterans' return to civilian life.
A sample of articles on the risk for alcohol use disorder, language comprehension in children with autism, varied skills, primate vocal communication, the importance of the context for child development, and the role of robots in understanding the human mind.
Perspectives and the Truth: Another Case for Diversity and Inclusion
Analyzing the mind as a computer has proved highly generative, but it may also overlook its interdependence with the environment, writes Shinobu Kitayama.
Primatology and Psychology, Shedding Light on Culture and Behavior
Frans de Waal explores the connection between primatology and psychology and how they intersect on issues of culture and behavior.
Simple comparative experiments reveal how shared intentionality and social coordination set humans apart from other primates, says APS Fellow Michael Tomasello.
12345...NextLast »


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Children's Commissioner faces "severe" investigation blocks
Charities and human rights experts have blasted Jersey's government for drafting a law that "falls well short" of international standards by severely restricting the Children's Commissioner's ability to investigate children's welfare issues.
States Members are due to debate the law that will underpin the role currently held by former police officer, teacher and Children's Services director Deborah McMillan tomorrow.
Ahead of that, however, serious concerns have been raised – including by the Children's Commissioner herself – that the law as drafted will leave her with no more power to probe government and non-government bodies over their care for children than a lay person.
Mrs McMillan has said in a critical letter to a Scrutiny Panel that, when she was involved in the drafting process of the law, specific instructions had been given to ensure she is given legal entitlement to any documents or information she requires to fulfil her duties – including, potentially, sensitive personal information.
But she says the Minister for Children then lodged an "entirely different version" of this rule, which is due to be voted on during tomorrow's States Assembly meeting.
Pictured: Mrs McMillan says the Children's Minister has put forward an "entirely different version" of her instructions which is due to be voted on by the States Assembly.
Under its current formulation, the law would allow Mrs McMillan the ability to request information in line with the Freedom of Information Law, which limits the release of 'personal information'.
It also means that any information released to her could be viewed and altered by the government's Communications team if deemed to pose a reputational risk, as Express revealed last week.
"This Law as lodged in effect limits the extent of the obligation on relevant authorities to disclose information to the Children's Commissioner," she wrote.
Pictured: In its current formulation, the law would allow the Children's Commissioner to request information in line with the Freedom of Information (FOI) law, which is subject to 'personal information' restrictions and possible review and alteration from the Communications team.
She added that the draft law "fails to deliver" on obligations imposed on the government in the wake of the damning Care Inquiry, which uncovered years of systemic abuse in island institutions, subsequently calling for "greater transparency and greater openness in communication… in order to tackle the perception of cover-up".
Mrs McMillan isn't the only one to have raised issue with the law.
Bruce Adamson, Scotland's Children's Commissioner, who, like other UK commissioners, is able to require "any person" to produce documents relevant to an investigation, described the law as leaving Mrs McMillan "with no more power to seek and receive information from public bodies than the average man or woman in the street".
"The rationale for this restriction is not clear to me. The role and mandate of a children's commissioner necessarily involves holding the organs of the state accountable to their human rights obligations. To effectively exempt public bodies from the scope of the Commissioner's investigatory powers severely limits her ability to fulfil that role and to protect children's human rights," he said.
Mr Adamson added that he expected that, if the law were to pass as drafted, it would be "likely to draw adverse comment" from the UN, Council of Europe and other international institutions.
These comments were echoed by a human rights expert, Dr Simon Hoffman, who is Coordinator of the Observatory on Human Rights for Children. He said the draft law placed "a severe… unacceptable fetter on the powers necessary to effectively safeguard children in Jersey from the harms that ensue when their rights are violated"
Local children's charity Brightly described the law as "significantly weaken[ing] the Commissioner's role and powers", while the island's Information Commissioner Jay Fedorak added that only allowing her to request information in line with FOI seemed "unnecessary".
He warned: "As a data protection advocate and regulator, I have no concerns about the Children's Commissioner being able to access relevant person information that she requires to perform her duties. Protecting children is in the public interest and an appropriate justification for possessing personal data under the Data Protection Law."
He further warned that pegging Mrs McMillan's role to the FOI Law could even pose a danger to children, as he would be asked to adjudicate on data release disputes, which could lead to delays.
Pictured: Concerns have been raised to a Scrutiny panel about the law governing the Children's Commissioner role.
"The timelines included in the FOI Law could lead to delays that put children at risk, particularly if a public agency were to challenge my decision in the Courts."
International charity UNICEF also carried a strong warning that the law put forward by the government was of "great concern", as it "fall[s] well short of the minimum international standards and can undermine the independence and effectiveness of the Commissioner for Children in Jersey".
It concluded its submissions to a Scrutiny Panel tasked with investigating the issue by calling for the draft law to be revised as a "matter of urgency".
Family Nursing and Home Care (FNHC), meanwhile, were in favour of the current proposals for the law underpinning the Children's Commissioner's role.
Adding that they already able to provide safeguarding information on request, the group, which is contracted to deliver significant child and family services on behalf of the Government of Jersey, said that the Commissioner's ability to request information under the draft law was sufficient.
The Children's Commissioner declined to provide any further comments, other than those contained in her letter.
The concerns follow a recent independent report that gathered the views of children in care in Jersey entitled 'Listen Louder'.
It found evidence of social workers "fighting" against Children's Services on behalf of children, "false promises" being made, as well as some children being called the wrong name – or even by their case number – to their face.
"One young woman spoke about having heard young people referred to by their case file number. She said: 'Call us a fake name, call us a fruit, call us anything, but not a number'. She felt acutely aware that often professionals didn't seem to care. Another young woman asked 'just treat us like a person'," the report noted.
Posted by	June Summers Shaw	on	Mar 25th, 2019
It is absolutely unacceptable that this law should be passed and I am extremely disappointed that FNHC find favour with it.
Who has responsibility for the drafting of this law and who made the change ? We have a right to know. To all those voting on it, if you care for the welfare of our children, vote it out.
If Jersey has nothing to fear and wants open and transparent government, give full access to the Children's Services director Deborah McMillan to all records.
Posted by	John Henwood	on	Mar 25th, 2019
Government either means what it says about the future approach to child care or it doesn't. This is not the time for weasel word; Ms McMillan was appointed to do an important job, so why withhold the tools that will enable her to do it properly and thoroughly. The States must learn to delegate authority, when it tries to do everything it usually cocks up.
Posted by	Lesley Ricketts	on	Mar 25th, 2019
States of Jersey has been a 'neglectful corporate parent' and now what they are worried about are compensation claims if Deborah McMillan has freedom to access records. The pledge to put children first is simply empty rhetoric.


Looking for a gorilla safari company to help you organize a tour to Bwindi Impenetrable National Park. Here is a listing of suggested tour operators organizing trips to Bwindi. Whether you are looking for a packaged holiday or just need a tour operator to help you book a gorilla permits, these companies will help you.
Most of the following tour operators provide tours into Bwindi Impenetrable National Park and the surrounding ecosystem.


A bracing walk . . .
. . . along the beach. Nothing quite like it. Today we walked along Woolacombe Beach to Putsborough and had a welcome cup of tea at the beach hut there, admiring the views . . .
. . . then climbed among the rock pools. I love the pinks, purples and greens of the rocks and stones . . .
Wonderful for the few of us on the beach enjoying the sea this afternoon . . .
Posted in wild and gardens. Tagged with beach, North Devon, Putsborough, Rock pools, sea, Woolacombe.


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My Box of Chocolates
Deon Cole
Laz Alonso
Rhonda Recommended
Director: Destin Daniel Cretton Writer(s): Destin Daniel Cretton, Andrew Lanham, Bryan Stevenson (novel) Starring: Michael B. Jordan, Jamie Foxx, Brie Larson, Rafe Spall, Tim Blake Nelson, O'Shea Jackson Jr., Rob Morgan, Darrell Britt-Gibson, Claire Bronson, Rhoda...
Could 'Just Mercy' Set a New Standard for Inclusion?
By Brent Lang | Variety Social justice activist and attorney Bryan Stevenson has done a lot in his 59 years on this earth. He's argued and won cases before the U.S. Supreme Court. He created a museum on the history of lynching, slavery and racial discrimination and a...
True Justice: Bryan Stevenson's Fight for Equality (2019)
Director: George Kunhardt, Peter W. Kunhardt, Teddy Kunhardt Writer(s): N/A Starring: Bryan Stevenson, Christy Stevenson, Howard Stevenson Synopsis: A look at how Alabama attorney Bryan Stevenson struggles to create more fairness in the legal system. Release Date:...
Michael B. Jordan Signs On To Just Mercy
By Tambay A. Obenson | Shadow and Act While we wait to catch his starring appearance in the upcoming "Fantastic Four" which will be in theaters next month, followed by his reunion with his "Fruitvale" director, Michael Coogler, in...
That Gal… Who Was in That Thing: That Guy 2 (2015)
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Albert & Sons International is located at the address 1878 The Elms Ave in Memphis, Tennessee 38127. They can be contacted via phone at (901) 353-6156 for pricing, hours and directions.
For maps and directions to Albert & Sons International view the map to the right. For reviews of Albert & Sons International see below.


Grandeur Peak Funds tries to keep annual distributions somewhat aligned with the returns of each fund. By doing this, the tax burden remains more equitable across the shareholder base, and new shareholders are not burdened with gains from previous years. However, our first priority is long-term performance of the funds, and so tax management is only done at the margins where it is consistent with our primary goal. We do not specifically manage the Grandeur Peak funds to be tax efficient.
The Record Date is the date at which Grandeur Peak takes a "snapshot" to see who holds shares in a particular fund for a distribution. All shareholders as of the Record Date will receive the declared dividend or capital gains distribution.
Regardless of whether you choose to receive fund distributions in cash or to have the distributions automatically re-invested in the fund, these distributions are taxable (unless your shares are held in a tax-deferred or tax-exempt account like an IRA). Consequently, you will receive a 1099-DIV form at the end of the year for each Grandeur Peak Fund you own that has pays a distribution. This form indicates the amount of distributions from a fund and should be included in your income tax return.


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Bruce Springsteen & The E Street Band "Magic" Tour 2007-08
Bruce Springsteen & The E Street Band reunited in 2007 after Bruce's two independent tours: the solo/acoustic Devils & Dust (2005), and Bruce Springsteen & The Sessions Band (2006).
The E Streeters were revved up and ready to rock to Bruce's nostalgic, highly personal new album, with its wide range of expression—from heavy guitars and social commentary to classic sixties flashbacks. The show lent itself to drama, as only Springsteen can deliver, and stadium-sized, exuberant showmanship.
This show gave us, as lighting and production designers, plenty of inspiration and lots of shiny surfaces to light. Bruce likes shadow, and we had a great time dishing it up, creating as much film noir as an arena show allows, and then some.
We were encouraged to expand our color palette. We also spent a lot of time making sure the show looked great on the video screens.
In 2008, Bruce took the show outdoors. This exponentially enlarged version of the arena show simply lifted off Earth at sundown and orbited for around four hours until Bruce allowed it to finally return home—but the audience would surely never be the same!
Lighting Designer:
Tour Lighting Director:
Associate Lighting Designer:
Kristie Roldan
Jason Badger
Equipment Vendor:
Morpheus Lights
Beyoncé "Bday" Live From Tokyo (AOL Music LIVE! & DirecTV)
Homecoming: The Kansas City Symphony Presents Joyce DiDonato
Bruce Springsteen: "Devils & Dust" Solo-Acoustic Tour
El Grito de México 2004 & 2005 (Univision)
Usher (ABC Family Special & DVD)
Bruce Springsteen & The E Street Band (Specials)
Buddy Holly: Listen to Me—The Ultimate Buddy Party (PBS)
A Celtic Awakening: Faith Marion Robinson
Bruce Springsteen & The Sessions Band – Live In Dublin
Anúna: Celtic Origins (PBS & DVD)
Bruce Springsteen & the E Street Band "Workin' on a Dream" World Tour 2008-2009
Live By Request – John Fogerty (PBS)
Bruce Springsteen: VH1 Storytellers
Alicia Keys, Unstaged: YouTube/Vevo & Fuse-TV Network


The combination of hull shape for river running and for play makes this Jackson Kayak 4Fun a great all around option; narrow for speed but flared out sidewalls and increased continuous rocker keeps your edges out of the water. This design allows you to keep more water off the deck, make the most of your boofs, and help you cross holes and eddy lines with authority, while the increased side-wall flair allows for added stability on edge, easier rolling, later bracing, and to reduce the effects of boils and cross-currents. Beginners like this boat because it's fun and easy to grow into. Intermediate and advanced boaters like it because it's difficult to outgrow.


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Q: How do I tell if a long running update won't lock the database? There is a update query I need to run on a table in production. The update would touch millions of rows and I would take a couple of minutes.
The database is Mysql.
I was wondering if the table would be locked during this update? The desired behaviour is that it should not be locked as I still want other operations to be possible while the update is going on.
Is there a way I can check before hand? What could I look for to find out the effect of such query? Is there something like a query plan from where I can see if the table would be locked or not?

A: Any UPDATE transaction will always acquire locks on the table being updated in some capacity. This is the normal default behavior in all modern relational database management systems. It's just a matter of the type of lock and how long a particular row stays locked during an UPDATE. Depending on the isolation level your database is configured for, even though a row may be locked, doesn't necessarily mean things like reads of that row will be blocked. You can read up more here on locks in MariaDB.
To your follow up question in the comments, depending on the isolation level, if an UPDATE is locking a set of rows that causes blocking on other subsequent queries running against those same rows, then those other queries will wait until those rows are no longer locked by the UPDATE query, to execute, in general.

redpajama_set_name: RedPajamaStackExchange


This khukuri derives it's name from from the Chainpur village in eastern Nepal. It is unique in that the notch in the blade is closed and the handle is different. This one has a beautiful rosewood handle and a water buffalo leather scabbard.It has a HIGHLY GRADED carbon steel blade which is strong enough to cut wood or bone! It has a full tang which means the metal of the blade fully goes through the handle for maximum strength. The craftsmanship on this knife is amazing so if you are looking for the finest quality khukuri you will not be dissapointed.This khukuri also includes 2 smaller knifes in the scabbard. A "Karda" which is used as a small utility knife. Also a "Chakmak" which is used to sharpen the knife. They also have rosewood handles on them.Kami Biswokarmas (Master Craftsmen)have used the best skillto hand produce each knife. ON AVERAGE IT TAKES 4 CRAFTSMEN 1 FULL DAY TO HANDCRAFT EACH KHUKUR.This knife comes wrapped in high quality handmade lokta paper. The paper is eco-friendly and made from the bark of the Daphne cannabina/papyracca tree.
Khukuri is Handicraft product. The actual weight/size on every product could be some grams/cm different than mentioned on the page.
Shipping weight for multiple product could be less than display on the page. Plz contact us with desire product code to know the total shipping weight before making Payment.


The OWL Ministry membership is for anyone who is 55+ years old and has the desire to be blessed and bless others through ministry activities. Our purpose is to promote spiritual, physical, intellectual, social and emotional growth through a variety of activities that challenge and stimulate senior adults to explore areas that will enhance healthy relationships and vital lifestyles that glorify God.
But as for you, speak the things which are proper for sound doctrine: that the older men be sober, reverent, temperate, sound in faith, in love, in patience; the older women likewise, that they be reverent in behavior, not slanderers, not given to much wine, teachers of good things- that they admonish the young women to love their husbands, to love their children, to be discreet, chaste, homemakers, good, to be obedient to their own husbands, that the word of God may not be blasphemed.


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BAHÁ'Í FAITH OF CHATTANOOGA TENNESSEE
Baha'u'llah
Abdu'l-Baha
Shoghi Effendi
Bahiyyih Khanum
Worship and Prayer
A Baha'i Blog - Please Comment
Videos - About Us
A Pivotal Time
A Positive Future
A Brief Overview
What Baha'is Believe
Humanity is one, and prejudices and patterns of life that block the expression of this fundamental truth are gradually falling away. We see evidence of this transformation all around us – the breaking down of the old, and the building up of new ways of being and social structures that contribute to the advancement of all people. Working towards this vision will require profound personal and social transformation over many generations. Humanity is leaving behind its childhood and entering a period of collective maturity.
A new understanding of human reality
A new understanding of religion
This transformation requires a new vision of the purpose and nature of religion. Religion is a faculty of the human soul that enables individuals to mine inner resources of courage, vision, and high endeavor. It allows groups and communities to explore reality together and forge a common vision and purpose. When harmonized with science, religion is a system of knowledge that propels the advancement of civilization.
Learning to put beliefs into action
Bahá'ís are striving to align themselves with the constructive processes that are informed by this fundamental oneness of mankind, religion, and God, and walk with all on a path of service to humankind.
The Youngest of the World's Major Faiths
The Bahá'í Faith is the youngest of the world's independent monotheistic religions. Founded in Iran in 1844, it now has more than seven million adherents in 236 countries and territories. Bahá'ís come from nearly every national, ethnic and religious background, making the Bahá'í Faith among the most-widespread religions in the world. Because Baha'is believe that God's guidance for humanity is a historic process that is and continues to be on-going, Baha'u'llah Divine Teachings are the latest in an eternal process.
Immerse yourselves in the ocean of My words, that ye may unravel its secrets, and discover all the pearls of wisdom that lie hid in its depths. Take heed that ye do not vacillate in your determination to embrace the truth of this Cause—a Cause through which the potentialities of the might of God have been revealed, and His sovereignty established. With faces beaming with joy, hasten ye unto Him. This is the changeless Faith of God, eternal in the past, eternal in the future. Let him that seeketh, attain it; and as to him that hath refused to seek it—verily, God is Self-Sufficient, above any need of His creatures.
Bahá'ís view the world's major religions as a part of a single, progressive process through which God reveals His will to humanity. Bahá'u'lláh (1817-1892), the Founder of the Bahá'í Faith, is recognized as the most recent in a line of Divine Messengers that includes Abraham, Moses, Krishna, Buddha, Zoroaster, Christ, Muhammad and the Bab.
The central theme of Bahá'u'lláh's message is that humanity is one single race and that the day has come for humanity's unification into one global society. While reaffirming the core ethical principles common to all religions, Bahá'u'lláh also revealed new laws and teachings to lay the foundations of a global civilization. "A new life," Bahá'u'lláh declared, "is, in this age, stirring within all the peoples of the earth."
Shrine of Bahá'u'lláh - Akka, Israel
A Brief Overview of the Bahá'í Faith
Some Bahá'í Practices
Daily prayer and communion with God.
Independent investigation of truth.
A life dedicated to the service of humanity.
A safe and non-judgemental approach to faith for all
Fellowship with the followers of all religions.
Some of our values: avoidance of partisan politics, excessive materialism, backbiting, alcohol, drugs, and gambling.
A non-judgemental approach to faith for all
Some Bahá'í Social Principles
Full equality between women and men in every level of society
Harmony between science and religion as two complementary systems of knowledge that must work together to advance the progress of humanity.
The elimination of all forms of prejudice.
The establishment of a world commonwealth of nations.
Spiritual solutions to economic problems and the removal of economic barriers and restrictions.
Pictures and some designs are gratefully acknowledged as from the National Spiritual Assembly
of the Baha'is of the United States
Copyright 2019~ Spiritual Assembly of the Bahá'ís of Chattanooga
2405 Hamill Rd, Hixson, TN 37343
secretariat@chattanoogabahai.org


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7.30 am on the coldest morning of the autumn (so far) isn't normally the ideal time to be up and about sightseeing, but if you want to see Billingsgate fish market, that's getting a bit late. And it is only a short bus ride away from me, so there's no excuse for not having visited before.
It's a prosaic shed (quite unlike its former building (now an upmarket conference centre) in the City), and it's tucked into a nondescript plot of land handy for the main road (but no doubt now eyed covetously by no end of property developers).
Once you're inside, the display of fish is as far from the average supermarket display as you could imagine, with whole huge fish and wholesale-size packages of processed products on every side. There are, of course, familiar products of our own waters, like dressed crab for £2.50, and those vacuum-packed kipper fillets with a lump of butter in; uneasy memories were stirred by the sight of a sign for coley (my mother would occasionally boil "six-pennorth of coley for the cat", which would drive the rest of us out of the house) - I had no idea they were such a big fish. But what caught my eye were the exotics, like parrot-fish, needle-fish with alarming green teeth, baby sharks, and the like. That, and the pile of salmon heads (4 for £1) that presumably someone might want for stock.
Eventually, the traders' banter was sounding a little forced, some of the stands were closing, and the pressure-washing of stands, trolleys and floor was moving rather pointedly towards people who were gawping and photographing rather than buying. So it was time for a scallop and bacon roll in one of the onsite cafés (sorry - caffs), and on with the rest of the day's business.
You get a politer class of graffiti at Marylebone ...
It was entirely a matter of chance that I walked u...
"Press button B"
And it's done..
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It begins....


text:
The most effective method to short-circuit the coronavirus immune system
In an upsetting corresponding to H.I.V., the coronavirus can cause a consumption of significant invulnerable cells, ongoing studies found.
Toward the start of the pandemic, the coronavirus seemed to be another respiratory ailment. In any case, the infection has ended up affecting the lungs, however the kidneys, the heart and the circulatory system — even, by one way or another, our faculties of smell and taste.
Presently analysts have found one more upsetting shock. In numerous patients hospitalized with the coronavirus, the safe framework is compromised by an exhaustion of certain basic cells, recommending shocking equals with H.I.V.
The discoveries propose that a famous treatment to pack down the insusceptible framework in seriously sick patients may support a couple, however could hurt numerous others. The exploration offers pieces of information concerning why not many youngsters become ill when they are tainted, and implies that a mixed drink of medications might be expected to manage the coronavirus, similar to the case with H.I.V.
Developing exploration focuses to "very complex immunological signatures of the virus," said Dr. John Wherry, an immunologist at the University of Pennsylvania whose lab is investigating the insusceptible frameworks of Covid-19 patients.
In May, Dr. Wherry and his partners posted online a paper indicating a scope of insusceptible framework abandons in seriously sick patients, including lost infection battling T cells in parts of the body.
In a different report, the specialists distinguished three examples of safe deformities, and reasoned that T cells and B cells, which help organize the invulnerable reaction, were latent in about 30 percent of the 71 Covid-19 patients they inspected. None of the papers have yet been distributed or peer reviewed.
Analysts in China have revealed a comparative exhaustion of T cells in basically sick patients, Dr. Wherry noted. In any case, the rising information could be hard to decipher, he said — "like a Rorschach test."
Research with seriously sick Covid-19 patients is laden with troubles, noted Dr. Carl June, an immunologist at the University of Pennsylvania who was not engaged with the work.
"It is hard to separate the effects of simply being critically ill and in an I.C.U., which can cause havoc on your immune system," he said. "What is missing is a control population infected with another severe virus, like influenza."
One of the more point by point considers, distributed as a preprint and under survey at Nature Medicine, was led by Dr. Adrian Hayday, an immunologist at King's College London.
He and his associates looked at 63 Covid-19 patients at St. Thomas' Hospital in London to 55 sound individuals, some of whom had recuperated from coronavirus contaminations.
Dr. Hayday and his associates started with the presumption that the patients would create a significant invulnerable reaction to the coronavirus. That is the reason the vast majority recoup from infections with hardly any, side effects.
In any case, the individuals who become exceptionally ill from the infection could have resistant frameworks that become debilitated on the grounds that they go overboard, as occurs in sepsis patients. On the other hand, the researchers theorized, these patients could have resistant frameworks that battle relentlessly, however neglect to react satisfactorily to the infection.
One of the most striking abnormalities in Covid-19 patients, the agents found, was a checked increment in levels of a particle called IP10, which sends T cells to regions of the body where they are required.
Commonly, IP10 levels are just quickly raised while T cells are dispatched. Be that as it may, in Covid-19 patients — just like the case in patients with SARS and MERS, likewise brought about by coronaviruses — IP10 levels go up and keep awake.
That may make riotous motioning in the body: "It's like Usain Bolt hearing the starting gun and starting to run," Dr. Hayday stated, alluding to the Olympic runner. "Then someone keeps firing the starting gun over and over. What would he do? He'd stop, confused and disoriented."
The outcome is that the body might be flagging T cells nearly at irregular, befuddling the resistant reaction. Some T cells are set up to annihilate the infections yet appear subverted, carrying on abnormally. Numerous T cells evidently kick the bucket, thus the body's stores are drained — especially in those over age 40, in whom the thymus organ, the organ that produces new T cells, has gotten less effective.
The research likewise proposes that a well known thought for treatment may not support a great many people.
A few patients are seriously influenced by coronavirus diseases in light of the fact that their safe frameworks react too energetically to the infection. The outcome, a purported cytokine storm, likewise has been found in malignant growth patients rewarded with drugs that supercharge T cells to assault tumors.
These eruptions can be suppressed with prescriptions that obstruct a particle called IL-6, another coordinator of invulnerable cells. In any case, these medications have not been particularly viable in most Covid-19 patients, and all things considered, Dr. Hayday said.
"There clearly are some patients where IL-6 is elevated, and so suppressing it may help," he clarified. In any case, "the core goal should be to restore and resurrect the immune system, not suppress it."
The new exploration may help answer another squeezing question: Why is it so uncommon for a kid to become ill from the coronavirus?
Kids have exceptionally dynamic thymus organs, the wellspring of new T cells. That may permit them to remain in front of the infection, making new T cells quicker than the infection can wreck them. In more seasoned grown-ups, the thymus doesn't work too.
The developing picture demonstrates that the model for H.I.V. treatment, a mixed drink of antiviral medications, might be a decent wagered both for those with mellow sicknesses and the individuals who are seriously sick.
A few specialists have thought about whether antiviral treatment bodes well for seriously sick Covid-19 patients, if their principle suffering is an insusceptible framework overcompensation.
Be that as it may, if the infection legitimately makes the invulnerable framework glitch, Dr. Hayday stated, at that point an antiviral bodes well — and maybe much more than one, since it's essential to stop the disease before it exhausts T cells and damages different pieces of the immune system.
"I have not lost one ounce of my optimism," Dr. Hayday said. Indeed, even without an immunization, he predicts Covid-19 turning into a reasonable illness, constrained by drugs that demonstration legitimately against the infection.
"A vaccine would be great," he said. "But with the logistics of its global rollout being so challenging, it's comforting to think we may not depend on one."
Topics #coronavirus immune system #COVID-19
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We should all do a complete detoxification at least once a month. That is especially recommended for people with health problems. Looks complicated?
Well, detoxification does not require any special effort, it is more like a routine, and in this article we will explain how to take advantage of its benefits. There are many ways to cleanse your organism, but we suggest that you use the power of apples to detoxify your body.
Detoxification is more than important, because due to poor dietary habits toxins build up in your digestive tract, and later spread through the whole organism. Apples are rich in pectin, and it is known to eliminate the toxic buildups in the intestines, after collecting them. It is an efficient and painless process.
How to cleanse your body properly?
Breakfast: Drink some fresh apple juice, without any sugar or sweetener added. Add some lemon juice; half a lemon is just enough. Use a blender to prepare the juice and drink it sip by sip, not all at once. Eat two apples, 2-3 hours after you have finished the apple juice.
Lunch: Make a tea using apple peels. Add two tablespoons of honey to sweeten it. Eat 2-4 apples one or two hours after the lunch. Drink fresh apple juice in the afternoon.
Dinner: Combine apple pulp (mashed apple, without the peel) and 2 tablespoons of honey.
The dinner is actually the final step of this detoxification process. It is important to remember that you must not eat anything other than apples throughout the day. Apples are easily digested, so you can greatly improve your overall health by detoxifying your organism more often.
Apple-based detoxification helps in the treatment of gout, rheumatism, arthritis, kidney problems, clogged blood vessels, it cleanses the blood vessels and eliminates fat from the blood. It also has a positive affect on the nervous system. This detoxification process will boost your metabolism and help you lose weight more easily.
Detoxifying your body once a month is an excellent prevention, but for better results you should repeat it more often, for example, three times a month. Make sure you chew the apples well, in order to use all the nutrients.
Of course, this does not mean that you should eat apples only during the detoxification process. Eat apples anytime you want, several times a day. You all remember the old saying "An apple a day keeps the doctor away," right?


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Q: How to create zip file with data-descriptor section Is there a way to create a zip file and to force it to have data-descriptor section from the command line?

A: In a comment on Github (https://github.com/adamhathcock/sharpcompress/issues/88#issuecomment-215696631), I found a suggestion to use the -fd flag:

Just FYI, when creating the ZIP file i also used the the command line parameter -fd which enforces usage of data descriptors. Not sure whether the ZIP tool on OSX provides this parameter, but i noticed that you didn't use it when creating your ZIP file

So I tested it (with the standard zip tool on OS X, "Zip 3.0 (July 5th 2008)"), and confirmed that it indeed generates a zip file with the data descriptor set, as follows:
/tmp> touch empty.txt
/tmp> zip -fd foo.zip empty.txt
  adding: empty.txt (stored 0%)
/tmp> xxd foo.zip
00000000: 504b 0304 0a00 0800 0000 698d 7c49 0000  PK........i.|I..
00000010: 0000 0000 0000 0000 0000 0900 1c00 656d  ..............em
00000020: 7074 792e 7478 7455 5409 0003 a65e 3c58  pty.txtUT....^<X
00000030: a65e 3c58 7578 0b00 0104 f501 0000 0400  .^<Xux..........
00000040: 0000 0050 4b07 0800 0000 0000 0000 0000  ...PK...........
00000050: 0000 0050 4b01 021e 030a 0008 0000 0069  ...PK..........i
00000060: 8d7c 4900 0000 0000 0000 0000 0000 0009  .|I.............
00000070: 0018 0000 0000 0000 0000 00b0 8100 0000  ................
00000080: 0065 6d70 7479 2e74 7874 5554 0500 03a6  .empty.txtUT....
00000090: 5e3c 5875 780b 0001 04f5 0100 0004 0000  ^<Xux...........
000000a0: 0000 504b 0506 0000 0000 0100 0100 4f00  ..PK..........O.
000000b0: 0000 5300 0000 0000                      ..S.....
The boldfaced sequence of 16 bytes above is the data descriptor section.
Its header 50 4b07 08 (or PK..) and the data descriptor format is specified by the zip specification (https://pkware.cachefly.net/webdocs/casestudies/APPNOTE.TXT):
  4.3.9  Data descriptor:

        crc-32                          4 bytes
        compressed size                 4 bytes
        uncompressed size               4 bytes

      4.3.9.1 This descriptor MUST exist if bit 3 of the general
      purpose bit flag is set (see below).  It is byte aligned
      and immediately follows the last byte of compressed data.
      This descriptor SHOULD be used only when it was not possible to
      seek in the output .ZIP file, e.g., when the output .ZIP file
      was standard output or a non-seekable device.  For ZIP64(tm) format
      archives, the compressed and uncompressed sizes are 8 bytes each.

...
      4.3.9.3 Although not originally assigned a signature, the value
      0x08074b50 has commonly been adopted as a signature value
      for the data descriptor record.  Implementers should be
      aware that ZIP files may be encountered with or without this
      signature marking data descriptors and SHOULD account for
      either case when reading ZIP files to ensure compatibility.

To find out whether the third bit of the general purpose bit flag is set, we have to parse the zip file to locate the file header for empty.txt.
See Wikipedia for a brief overview and tables describing the meaning of bytes in a zip file - https://en.wikipedia.org/wiki/Zip_(file_format) .
The last 22 bytes (starting at the penultimate line, 504b 0506 (or PK..) is the end of central directory (EOCD) record. At offset 16 within this EOCD record, a 4-byte unsigned integer specifies the start of the central directory. We have 5300 0000 (little endian), or 0x53 = 83. This happens to be the offset right after the data descriptor section that we have identified above. Starting at the 6th offset after the start of the central directory, we find a pair of bytes that form the bit flag.
0a 00 (little endian) = 00000000 00001010 (binary, big endian)
                                     ^
                            bit 3 of the general purpose flag

Indeed, the third bit (counting form the right, starting at 0) is set, so we see that the zip file created above indeed has a data descriptor section.


WE ARE LOOKING FOR YOUNG PEOPLE IN ISLINGTON WHO ARE INTERESTED IN APPRENTICESHIPS IN SITE ENGINEERING, CARPENTRY OR STEELFIXING.
Over the duration of the development we are aiming to provide 61 apprenticeships to young people who live in the borough of Islington and are keen to learn and develop their knowledge of construction.
At the current stage of our development, we have Expanded on site who are our ground works and frame contractor for Phase 1. They are looking for young people who are working towards or are interested in doing an NVQ qualification in civil engineering, carpentry or steel fixing.
If you are living in the London borough of Islington and interested in applying for an apprenticeship we want to hear from you.
We are always keen to hear from young people who are wanting to learn or develop their skills as a Site Engineer. If you are interested please email your CV and cover letter to james.baird@berkeleygroup.co.uk and we will let you know if any positions are available at this time.
We are always keen to hear from young people who are wanting to learn or develop their skills as a Carpenter. If you are interested please email your CV and cover letter to james.baird@berkeleygroup.co.uk and we will let you know if any positions are available at this time.
We are always keen to hear from young people who are wanting to learn or develop their skills as a Steel Fixer. If you are interested please email your CV and cover letter to james.baird@berkeleygroup.co.uk and we will let you know if any positions are available at this time.


After the surveys one of the chief complaints mentioned was how much of a struggle it is to gather and sort the dirty laundry from all over the house, especially if there were other members in the household who refuse to put their laundry in the designated area.
How Do You Deal With Laundry?
I don't know about you but laundry is one of the most difficult (and neverending) tasks I face everyday.
Just when I believe it's caught up another load (or 4) "magically" appears.
After putting out a few feelers in some of our support group, using my own struggles and getting our readers suggestions as a base I believe I have developed a comprehensive list of adaptations, tools and shortcuts to help make each load a little easier.
Mondays & Fridays in the month of March and April will be devoted to sharing some of the tips and tricks we have discovered.
My plan is to address these as thoroughly as possible here on the blog over the next few months if you have any specifics you struggle with or suggestions to make any household tasks easier please leave a comment below.
If you would like your comment to remain "private", please type. Private at the beginning of the comments.


The Sales Representative reports to Branch Manager. This position will play an integral role in communicating with our current clients which will include visits to client locations. The successful candidate will also be responsible for building additional new business. The ideal candidate must have experience in a similar position and have a professional manner with the ability to deal with a diverse group of people.


text:
Maharashtra: Why vegetable prices are hitting the roof
Supply disruptions fuel price rise as wholesalers go on an indefinite strike
Prices of vegetables and fruits have skyrocketed in the last two days in Mumbai and its suburbs on supply disruptions following an indefinite strike by wholesalers in nearby mandis against the Maharashtra government's proposed move to cut their trade commissions.
Retail prices of vegetables have jumped by up to 40 per cent since wholesalers decided to go on strike on Tuesday.
After hitting Rs 100 a kg, tomato slumped to Rs 60 on government intervention but the price bounced back to Rs 85 a kg due on lack of supply.
With an overall weight of 1.74 in the wholesale price index and 6.04 in the Consumer Price Index, rising vegetables prices may push food inflation.
Ahead of a move to delist fruits and vegetables from the Agricultural Produce Markets Committee, the Maharashtra government has registered over 700 farmers producers companies in the last few months for smooth distribution of fruits and vegetables in the state.
FPCs procure fruits and vegetables directly from farmers and distribute them among themselves for retailing.
But they cannot meet the entire supply of around 3,000 tonnes of green vegetables for Mumbai and its suburbs. Supply has remained deficient by at least 50 per cent, resulting in the price rise.
"Direct selling will benefit farmers and consumers," said Shri Ram Gadhave, president of the Vegetables Grower Association of India.Farmers receive an estimated 35-40 per cent of the price of vegetables paid by consumers.
Vegetable wholesalers are protesting against the government's proposal to restrict them from collecting eight per cent commission from farmers.
"We pay farmers upfront and buy in bulk without any security.
"We also help farmers with their livelihood or medical expenses.
"A commission of eight per cent is the only source of income from our investment, we cannot simply do charity," said Sanjay Bhujbal, a vegetable vendor at the Vashi APMC.
A little away from the city in the northern suburbs, vegetables are 15-30 per cent costlier.
Apple sells for Rs 160-200 a kg, a rise of nearly 20 per cent in two days.
Vegetable prices started firming up early this year on low production in a drought year.
Vegetable prices rose 60 per cent in New Delhi, Kolkata and Chennai.
The Maharashtra government convened a meeting of wholesalers, which remained inconclusive. It has decided to discuss the issue again on Thursday.
Image: A vendor accepts money from a customer at his vegetable stall at a wholesale fruit and vegetable market in Mumbai. Photograph: Vivek Prakash/Reuters
Dilip Kumar Jha in Mumbai


Springfield was such a cool little town and found ourselves exploring as often as we could.
One of our favorite places we went to while we were there was the Discovery Center.
Our boys still talk about the Discovery Center ALL the time. It's a four story building full of a whole lot of fun and learning. Both Ev and I were really impressed with it. They had things from digging up dinosaur bones, to how our bodies work, also a few favorites was the airplane exhibit, the giant legos and discovery town.
This was also a really fun floor! We spent a lot of time here learning about some of the different cultures, something both Ev and I are very interested in and excited to continue teaching our kids as they get older.
I Think this was one of my favorite rooms in the museum. Nixon's too. Since he was little he would point out anytime someone had "glittered" (littered). It always made me so happy he was noticing that at such a young age! He still brings it up and now will say things like "that's not being nice to our earth" or "why didn't they just put it in the trash can?" That's a gooood question Nixon buddy.
Just the other day he came up to me and says, "mom, we should start putting all our scrap food in a bucket and save it to make compost for our garden!" Pretty smart for a five year old if you ask me.
After the museum, we headed home for hot cocoa by the fire.


text:
2020 TaxPub(DT) 3878 (Del-Trib)
IN THE ITAT, DELHI BENCH
KULDIP SINGH, J.M. & PRASHANT MAHARISHI, A.M.
Steria (India) Ltd. v. Addl. CIT
ITA Nos. 741, 3992/Del/2017, ITA No. 5745/Del/2018 and SA Nos. 250-252/Del/2020
Assessee by: Ajay Vohra, Sr. Advocate, Neeraj Jain, Advocate, Akshay Uppal, C.A., Shailey Gupta, C.A.
Department by: Anupam Kant Garg, CIT DR
Prashant Maharishi, A.M.
1. ITA No. 741 (Del) of 2017 is filed for assessment year 2012-13, I.T.A. No. 3992 (Del) of 2017 is filed for assessment year 2013-14 and I.T.A. No. 5745 (Del) of 2018 is filed for assessment year 2014-15 by M/s. Steria (India) Limited, (The assessee/Appellant). As some common issues are involved, for the sake of convenience, these were heard together, and are being disposed of by this consolidated order. Stay petitions were also heard on 17-7-2020, which are also disposed of by this order for all these years.
2. ITA No. 741/Del/2017 for assessment year 2012-13 is filed by the assessee against the assessment order passed under section 143(3) read with section 144C of the Income Tax Act, 1961 [the Act] dated 5-12-2016 passed by the Additional Commissioner of Income Tax, Special Range-8, New Delhi (the learned Assessing Officer/AO) wherein the returned income of Rs. 1,132,764,370 filed by the assessee on 29-11-2012 is assessed at Rs. 1,515,053,700. The assessee has raised following grounds of appeal :--
'1. That the assessing officer erred on facts and in law in completing assessment under section 144C read with section 143(3) of the Income Tax Act ('the Act') at an income of Rs. 151,50,53,700 as against the returned income of Rs. 113,27,64,370 under normal provisions of the Act.
Transfer Pricing issue:
2. That the assessing officer/DRP erred on facts and in law in making an adjustment of Rs. 11,70,02,000 to the arm's length price of the 'international transaction' of provision of IT enabled services on the basis of the order passed under section 92CA(3) of the Act by the Transfer Pricing Officer ('TPO').
2.1 That the DRP/TPO erred on facts and in law in not appreciating that the appellant being a routine back office support service provider cannot be compared with companies engaged in provision of Knowledge Process Outsourcing ('KPO') Services for the purpose of benchmarking analysis.
2.2 That the DRP/TPO erred on facts and in law in considering Acropetal Technologies Ltd. (Seg.) as comparable for the purpose of bench marking without appreciating that the company is not functionally comparable to the appellant.
2.3 That the DRP/TPO erred on facts and in law in considering following companies in the final set of comparable for the purpose of bench marking analysis not appreciating that these companies are not functionally comparable to the appellant in terms of Rule 10B(2) :--
(a) Eclerx Services Ltd.
(b) Infosys BPO Ltd.
(c) TCS E-Serve Ltd.
(d) Informed Technologies Limited
(e) BNR Udyog Ltd. (Seg.)
2.4 That the DRP/TPO erred on facts and in law in considering following companies in the final set of comparable companies without appreciating that companies with such high turnover does not satisfy the test of comparability laid down under rule 10B(2) of the Income Tax Rules, 1962, for being operating in different market conditions and level of competition :--
(a) Infosys BPO Ltd.
(b) TCS E-Serve Ltd.
2.5 That the DRP/TPO erred on facts and in law in considering following companies which are earning exceptionally high margin when it should be appreciated that a company engaged in provision of routine BPO services cannot be expected to earn such high operating margins :--
(a) BNR Udyog Ltd. (Seg.)
(b) Eclerx Services Ltd.
(c) Infosys BPO Ltd.
(d) TCS E-Serve Ltd.
2.6 That on the facts and circumstances of the case and in law, the DRP erred in accepting Infosys BPO Ltd., TCS E Serve Ltd. and eCLerx Services Ltd. as comparable companies not appreciating that such companies were rejected as comparable by the DRP in the earlier assessment years holding them to be functionally dissimilar to the assessee
2.7 That the DRP/TPO erred on facts and in law in not allowing appropriate risk adjustment to establish comparability on account of the appellant being a low-risk-bearing captive service provider as opposed to the comparable companies who were independent software service provider.
2.8 That on the facts and in the circumstances of the case and in law, the DRP/TPO erred in rejecting the contention of the assessee regarding risk adjustment, allegedly holding that the computation of risk adjustment provided by the assessee is vague and without any basis.
Corporate Tax Issues:
Disallowance of Management Services Fees
3. That on the facts and in the circumstances of the case and in law, the DRP/assessing officer erred in disallowing under section 40(a)(i) of the Act, expenditure of Rs. 20,03,73,067 incurred on account of management services fees, allegedly on the ground that the appellant failed to deduct tax at source therefrom under section 195 of the Act.
3.1 That the DRP/assessing officer erred on facts and in law in holding payment made to Groupe Steria SCA ('Steria France') towards management services fees to be in nature of fees for Technical services ('FTS') in terms of Article 13 of India-France Double Tax Avoidance Agreement ('the DTAA').
3.2 That the DRP/assessing officer erred on facts and in law in erroneously relying upon the order of the Authority of the Advance Ruling ('AAR') without appreciating that the findings of AAR are perverse in light of the favorable order passed by the jurisdictional Delhi High Court in appellant's own case, thereby resulting in gross violation of the principles of natural justice.
3.3 Without prejudice, the DRP/assessing officer erred on facts and in law in not appreciating that the payment for managerial services to Groupe Steria is not covered under the term 'technical' or 'consultancy' services, prescribed in Article 13 of the DTAA.
3.4 That the DRP/assessing officer erred on facts and in law in not appreciating that the said services provided by Steria France does not 'make available' technical knowledge', experience, or skill to the appellant, in order to be taxed as FTS in terms of Paragraph 7 of the Protocol read with Article 13 of the India-UK DTAA.