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Friday, December 30, 2016

2016 Highlights

Politics, economics and markets were all turned on their head in 2016, and investors are looking ahead to 2017 following a turbulent year. Highlights: The Panama Papers, Diesel Gate settlement , Greek debt relief, Megabrew, the EU's tax crackdown, sale of Yahoo , nuclear test and impeachment in Korea, Pokemon Go, Twitter  takeover rumors, Brexit and sterling's plunge, the Italian referendum, panic at Deutsche Bank  and Monte dei Paschi , OPEC's output deal, and following Donald Trump's election - a Fed rate hike, the dollar's surge and soaring treasury yields. The Dow, S&P and Nasdaq also partied like it was 1999 - the three markets all closed at historic highs for the first time in 17 years.

Friday, December 16, 2016

China ceeded as number one Creditor following decline in holdings of US treasury.

Japan has overtaken China as the biggest holder of U.S. government bonds, as figures for foreign ownership of U.S. Treasurys in October show that China's holdings declined to the lowest in more than six years as its central bank used its foreign exchange reserves to support the yuan. Japan's Treasury holdings also decreased but at a slower pace; Japan trimmed $4.5B of U.S. paper to end the month with $1.131T, while China's holdings plunged by $41.3B to $1.115T, the lowest level since July 2010 and capping a decline of five straight months. China has been dipping into its reserves, selling Treasurys to support the yuan, which yesterday fell to its weakest level vs. the U.S. dollar in more than eight years.

Global Currency Market recover against dollar

Global Market stable overnight, and the euro, yen and pound all recover a bit of ground against the dollar, as the greenback surged to 14-year highs vs. the euro and a broader basket of currencies yesterday as markets repositioned for a faster pace of Fed rate hikes over the next year. The yen has plunged 11% vs. the dollar since Pres.-elect Trump's election victory last month, surpassing the Mexican peso's 10% slide to become the worst performing major currency during the period. The weaker yen will make Japan’s exports more competitive and could boost growth, and the Nikkei index has gained for eight straight days, but bond prices have been under pressure amid a global debt selloff. In China, fears that a rising dollar will destabilize trading in the yuan has sent the currency to its lowest against the dollar in more than eight years and raised concerns that outflows could increase

Monday, December 12, 2016

Fed Outlook on rate hike?

The yield on 10 year Treasury Note is above 2.5% for the first time since October 2014, as investors eye a key Federal Reserve meeting which begins tommorow. The next notable yield is 3%, last hit in 2013. In equities: U.S. stocks are at all-time highs, with the Dow in striking distance of 20,000, but futures are sliding lower to start the week. Will expectations of a Fed rate hike put a dent in the Trump rally?

Fed Outlook on rate hike?

The yield on 10 year Treasury Note is above 2.5% for the first time since October 2014, as investors eye a key Federal Reserve meeting which begins tommorow. The next notable yield is 3%, last hit in 2013. In equities: U.S. stocks are at all-time highs, with the Dow in striking distance of 20,000, but futures are sliding lower to start the week. Will expectations of a Fed rate hike put a dent in the Trump rally?

Tuesday, November 15, 2016

The Green back continues to strength

The Green back continues to gain strength on expectations of higher interest rates under Trump, pushing the yuan to a near 8-year low and taking its losses so far this year to more than 5%. The People's Bank of China set its daily fix at 6.8495 yuan against the dollar, compared with Monday's 6.8291 yuan, marking the weakest fix for the currency since 2008.

Monday, November 14, 2016

U.S Bond yields are sharply higher

Bond yields across the board following a public market holiday on Friday, as traders continue to eye upward inflation trends following the election of Donald Trump. The yield on the benchmark 10-year Treasury note is 15 bps higher at 2.27%, while the 30-year Treasury bond yield is over 3% for the first time since January. The movement has also lit a fire under the greenback, with the U.S. dollar index up more than 1%, hitting 100 for the first time in almost a year.

Wednesday, November 9, 2016

Global Equity market witness sell off

It's an historic day for the United States, but it may not be one for the markets. Global equities initially cratered on word of a Trump presidency, even triggering safety breakers on U.S. index futures, but have pared losses. Dow futures are now about 400 points lower, while the S&P and Nasdaq are down over 2%. The tone is certainly negative, but this is not a Brexit reaction. 

The Mexican peso was hit hardest, tumbling as much as 13%, while the U.S. dollar plunged against the euro, yen and Swiss franc.

Tuesday, November 8, 2016

Key Takeaways from US Presidential Elections

What Investors want to know from US Elections

  • Clinton shares many of the Democratic Party's traditional views on spending and taxes, but Trump is generally not as fiscally conservative as a typical Republican
  • Regardless of who wins, Congress will decide which policies become reality - and the vast majority of Congressional seats are in play
  • A Clinton victory could result in a sell-off of pharmaceutical, biotech and possibly financial-services stocks
  • A Trump win could result in a short-term sell-off in stocks, a flight to gold and a rise in the US dollar.

      To understand the impact a Hillary Clinton or Donald Trump win could have on these areas, we must first examine the platforms of the two candidates in a variety of key areas - albeit with the caveat that their platforms have changed over time, particularly Trump's.


     Government spending





    • In this "all bets are off" election, investors might want to prepare for more volatility by increasing their focus on tactical asset allocation and sector allocation - and on downside protection.
    • Investors may also want to take a close look at the risk-mitigation and diversification benefits that alternatives provide.
    • It continues to be important to pursue alpha with active management, since beta returns are set to be low and volatile, which could undermine cheap index investments.



Tuesday, November 1, 2016

Standard Chartered Becomes Frst Commercial Issuer Of SDR Bonds In China

The IMF in November announced plans to add the yuan to the U.S. dollar, the euro, the Japanese yen and the British pound in its elite basket of global reserve currencies, which are widely used in trades and held by governments and institutions as a foreign exchange reserve.

On August 31, in what was dubbed a "historic event", the World Bank became the first issuer of bonds denominated in SDR and settled in yuan when it sold 500 million SDR units worth of bonds in China. Then, overnight, in yet another historic event, Standard Chartered Bank (Hong Kong) said on Friday that it has obtained approval from the People’s Bank of China to be the first commercial issuer of bonds denominated in Special Drawing Rights (SDRs) in China’s interbank bond market.

According to Reuters the size of the issuance programme is 100 million SDRs – approximately 925 million yuan, or $139 million – and the bonds will be settled in yuan. 

A successful offering would mark the first ever time a commercial issuer has issued securities have been issued in the synthetic reserve currency in 35 years.

“SDR bonds, to be settled in RMB, will help promote SDR financial instruments, provide a channel for investors to invest in foreign currency bonds in the onshore market, and offer more diversified bond products in the market."

 “The impact of the bond is very small as the size is tiny in comparison to US dollar denominated bonds and the secondary market for SDR bonds is non existent since this is the first of its kind issued in over 30 years.”
 And now that an alternative issuance currency is needed, the IMF's SDR will be happy to step in those shoes, or at least try, as it attempts to become, at first tentatively, to become a new global currency, one which - however - will need a lot of support from an establishment funded in the US currency to displace the greenback as the world's reserve currency, especially since it remains unclear how China feels about floating the Yuan and making it a truly international, and thus competitive, currency.

 The IMF also announced the weight of the five currencies within the basket – the percentage of each based on its relative importance in the world's trading and financial systems – would be set at 41.73 percent for the dollar, 30.93 percent for the euro, 10.92 percent for the yuan, 8.33 percent for the yen, and 8.09 percent for the pound.

 Currency components of the IMF's special drawing rights

S. 45/48: In valuing the shares of a privately held co, the “enterprise valuation” has to be taken by valuing even the assets held by subsidiaries of the Company. It is common for the sellers to charge a “controlling premium” for the sale of the shares. Such transfers to enable restructuring and re-aligning the shareholding pattern are genuine and bona fide. The alleged excess consideration for the sale of the shares cannot be treated as “unexplained income”

Amritlal T. Shah vs. ITO (ITAT Mumbai)

The exit from the closely held company BEC Industrial Investment Company Private limited with its subsidiaries could in commercial parlance definitely command premium in addition to the normal price based on NAV as first of all the valuation of the subsidiary would get embedded in the price of share of BEC Industrial Investment company Private Limited and that valuation has to be done based on present value of enterprise and not necessarily the book value as represented by financial statements and also controlling premium is embedded in the price for the shares paid by acquiring shareholders to the selling shareholder group to vest/strengthen their control in the BEC Industrial Investment Private Limited which shall get embedded in mutually agreed negotiated price between the buyer and the seller

Sunday, October 16, 2016

S. 2(47)(v): Entire law on whether entering into a "joint development agreement" with the builder and handing over possession/ power of attorney amounts to a "transfer" and gives rise to capital gains explained. Chaturbuj Dwarkadas Kapadia 260 ITR 491(Bom) explained/ distinguished

ACIT vs. Jawaharlal Agicha (ITAT Mumbai)

  It is generally seen that there may be several stages or events arising in a joint development arrangement made between owner of the land and the developer. For the purpose of determining the actual date of transfer of the land by the land owner, all these stages / events needs to be collectively analsysed and after evaluating overall effect of the same we can determine the actual date of transfer. These stages / events may be described as date of entering into JDA, date of executing power of attorney authorizing the developer for taking various approvals / permissions etc., handing over the possession of the land to the developer for various purposes, receipt of part / full sale consideration from the developer, date of execution of power of attorney in favour of developer authorizing him for the sale of developed units to the customers at his absolute discretion; and transfer of developed units to the customers etc. There may be few more stages / events to complete the transaction. Though, one single event may trigger the process of transfer but may not necessarily complete it also. Whether the transfer has, in substance, taken place, can be determined by analyzing the inter-play and effect of all these stages / events combined and put together. For example, possession may be given for various purposes, viz. possession given to a contractor, or to a tenant also, but such an event in itself cannot be regarded as “transfer” of land. Possession of land may also be handed over as licensee only for the purpose of development of real estate on land. Here again, it shall not give rise to “transfer”. Thus, when the possession is given along with other legal rights to the developer resulting into entitlement of the developer for full use and enjoyment of the property as well as its further sale after converting it into developed units at its full, own and sole discretion, then it may result into ‘transfer’ provided other conditions also suggest so. Thus, handing over of the possession has to be necessarily coupled with the intention of transferring the rights of ownership and enjoyment of the property to the developer. Handing over of the possession for the limited purpose of developing the land while still retaining the ownership and control of various legal rights upon the property by the land owner would not fall in clause (v) of section 2(47)

Thursday, July 7, 2016

The U.S surpass Saudi Arabia & Russia on Oil reserves

The U.S. holds more oil reserves (264B barrels) than Saudi Arabia (212B) and Russia (256B), the first time it has surpassed those held by the world's biggest exporting nations, according to a new study by Rystad Energy. The analysis of 60K fields worldwide, conducted over a three-year period, shows total global oil reserves at 2.1T barrels. That is 70x the current production rate of about 30B barrels of crude per year.

Tuesday, June 28, 2016

U.K 10 year yield slide record low after Moody's downgrade country rating to negative

U.K. 10-year Gilt yields have dropped below 1% for the first time to hit a new record low. The fall came after Moody's downgraded its U.K. sovereign rating to negative from stable, citing diminished policy predictability and economic effectiveness. Meanwhile, 10-year U.S. Treasury yields have extended their fall to 1.47%, tumbling 10 basis points this session.

Wednesday, June 8, 2016

Mario Draghi starts his corporate-bond buying program ow, he's pushed down borrowing costs in Europe toward unprecedented levels, with the average yield on euro investment-grade company notes tumbling to 1%. "The prospect of average yields below 1% is very scary, "Investors are being pushed outside their comfort zone to sectors like high-yield debt, where they may not have expertise."
The Reserve Bank of India also kept its key lending rate unchanged - at 6.5% - stating it would monitor economic developments for any further actions.Australia's Central Bank held its powder dry overnight as the nation's robust Q1 report card curbed the need for additional monetary stimulus. The RBA left its benchmark cash rate unchanged a month after it unveiled a 25 basis point cut, which took rates to their current record low of 1.75%.

Thursday, June 2, 2016

Japanese stocks fell by 2.3%

Nikkei fell by the most in a month overnight and the yen strengthened after Prime Minister Shinzo Abe moved to delay a sales-tax hike for more than two years. There are also concerns that the postponement could lead to a credit rating downgrade, increasing the cost of foreign funding and further raising doubts over the sustainability of the nation's public debt - which currently exceeds 200% of its GDP. Nikkei -2.3%.

Thursday, May 26, 2016

The PBOC lowered the yaun's reference rate by 0.3%

China's Central Bank lowered the yuan's reference rate by 0.3% to 6.5693 per dollar overnight, marking the currency's weakest level against the greenback since March 2011. The move could increase tensions between China and its trading partners, as recent strength in the dollar and yen make exports from those countries less competitive globally.

Friday, May 20, 2016

Global stocks fell to a six-week low

 Global Equity stocks ,sovereign bonds slumped and the dollar held gains after minutes of the Fed's last meeting put the prospect of a June rate hike firmly on the table so long as economic data continues to show positive signs. Oil is under pressure from the financial movement, in addition to EIA data showing a build in U.S. crude inventories, as well as surging output from Iran to Europe and Asia.

Monday, May 9, 2016

Transfer Pricing: Corporate Guarantees are not comparable to Bank Guarantees & so the commission of 3% charged by Banks is not a benchmark to evaluate the ALP of a corporate guarantee but it has to taken at 0.5%. ITAT decisions which upheld the 3% rate cannot be followed as they are contrary to Everest Kanto 378 ITR 57 (Bom)

Thomas Cook (India) Limited vs. ACIT (ITAT Mumbai)

Instances of commercial banks providing guarantees could not be compared to instances of issuance of corporate guarantee. When commercial banks issue bank guarantees, the same is quite distinct in character, than the situation where a corporate issues guarantee to the effect that, if a subsidiary associated enterprise does not repay a loan, the same would be made good by such corporate. It is quite clear that the manner in which the Transfer Pricing Officer has proceeded to determine the arm’s length rate based on the probable rate being charged by the commercial banks is not justified. In this view of the matter, we are unable to approve 3% rate of guarantee commission fee determined as arm’s length rate by the income-tax authorities. In the alternative, the addition that is required to be sustained is the position canvassed by the assessee before the Transfer Pricing Officer i.e. adoption of 0.50% as arm’s length rate for the purpose of determining the arm’s length income on account of guarantee commission fee in the present case 

Friday, May 6, 2016

Thoughts on Current market conditions

What an interesting two months we have seen in the market.  Although I wasn't expecting to see one of the biggest rallies the S&P has ever seen in such a short amount of time, my overall mid-term (1-3 years) bearish opinions haven’t changed.  One of the most interesting aspects of the recent rally is that despite companies across the US having terrible earnings calls after the first quarter, investors weren't rattled (so far).  For me, this is the bigger issue.  From a fundamental level, growth continues to slow, profit margins continue to decrease, and international markets continue to struggle (particularly the Bank of Japan, the PBOC, and European Banks).  Although the market could even run higher, I think the upside to downside risk/reward continues to be asymmetrical.

Now, one of the more interesting developments in the market is the FED’s change in forward guidance.  At the start of 2016, the FED was saying they would raise rates four times throughout the new year.  As months progressed, the FED continued to distance itself from being so aggressive.  I believe this is one of the main reasons we have seen the sharp recovery over the past few months.  This “dovish” talk has caused the dollar to lose value (relative to global currencies), which obviously gives US equities the hope for better numbers in the coming quarters (a big if).  Now, where this gets very concerning for me is Japan, Europe, and China.  If the dollar continues to weaken, the Japanese Yen (and other currencies) get stronger.  This has really caused some interesting circumstances for the disastrous monetary policies in Japan in particular.  I think this pressure has the potential to cause major issues in the coming quarters if the Yen continues to get stronger.  This could also cause second and third order effects in the international markets.  One of the benefits of the dollar weakening is that oil is making a very strong comeback (assuming you own oil companies).   I still haven’t taken a position in any oil companies (which might be the wrong decision).  For me, the bigger concern moving forward isn’t the oversupply; it’s the future demand.
Some global risk items and concerns to watch for in the coming quarters:
  1. The impact of negative rates for banks in Europe (Particularly Deutsche Bank)   
  2. A strong Yen pushing Japanese stock prices lower
  3. Chinese Commodity prices returning to reality (because the PBOC pushed commodity prices into outer space during the first quarter)
  4. Potential impacts of the Saudi currency de-pegging from the US dollar due to the speed and impact of their domestic reserves being spent.  Could cause the dollar to strengthen and put more pressure on US Stocks.
  5. Watch the 2nd quarters US earnings trends.  If earnings continue to slip into the second quarter, things could get ugly for US Stocks.
  6. Brexit: This could be a big concern for trade and US stocks.
  7. High yield debt.  The oil industry supposedly has 3 trillion or more in debt with as much as 50% being estimated as junk.  Some really interesting things could happen here if global demand continues to slip in energy and prices start heading lower again.  I think this is a major concern moving forward, but there is no way of knowing if this trend will return for sure.  My expectation is that it will, but who knows at this point.   
Anyway, those are a few big items that got my attention.  I think individuals should be aware of these possibilities to mitigate potential risks in your portfolio. I hope that helps.

Wednesday, May 4, 2016

The Economic recovery in Euro zone will be at slower pace due to subdued growth globally

Euro zone growth will be slower than previously expected with subdued inflation in 2016, the European Commission announced in its spring economic forecast, warning of high risks to the bloc's economy. The GDP of the 19-nation area is now predicted to expand just 1.6% this year, less than the 1.7% growth of 2015, while consumer prices are seen up 0.2%, significantly below the 0.5% increase projected in February. "The economic recovery in Europe continues but the global context is less conducive than it was. 

Sunday, May 1, 2016

Economies in Europe are firming towards slow recovery

Major Economies in Europe are showing some firming up as they stay on the slow road to recovery. The unemployment rate in Italy fell to its lowest level in over four years during March as the economy continued to grow. The jobless rate fell to 11.4% to beat the consensus estimate of analysts of 11.6%. GDP in Italy rose 0.3% in Q1. A bounce in consumer spending in France helped GDP expand to 0.5% in Q1, to top estimates for 0.4% growth. Meanwhile, Spain is expected to hit its target of 1.5% growth in Q1. Eurozone Q1 GDP rose 0.6% vs. 0.4% expected. The GDP mark was 1.6% higher than a year ago.

Wednesday, April 27, 2016

Apple stock hurts the sentiment of US market

Apple's share were down by 7.2% pre market,after the company's FQ2 results missed already low expectations. EPS was $1.90, profit fell to $10.52B from $13.57B, and revenue dropped 13% to $50.6B for Apple's (NASDAQ:AAPL) first sales decline  with revenue in Greater China dropping 26%. iPhone volumes fell for the first time, slumping to 51.2M from 61.2. Adding to the woe, Apple CEO Tim Cook gave a weak outlook, although he believes the "future is very bright." The question is whether he's right and the bull run will resume, or has Apple become a normal company again?

Wednesday, April 20, 2016

Oil futures down by 2.8% to $39.94

Crude prices have fallen below $40 a barrel after Kuwaiti oil workers ended a three-day strike that had cut the OPEC member's production by nearly half. Concerns about oversupply were further reinforced by API industry data that showed a 3.1M barrel U.S. inventory build last week, about double that expected by analysts. Bearish sentiment is also taking hold as traders continue to assess the impacts from the output freeze deal failure between major producers unday. Oil futures -2.8% to $39.94.

Looking to counter dwindling, oil revenues and reserves, Saudi Arabia is raising $10B from a consortium of international banks as it embarks on its first global debt issuance in 25 years. The landmark five-year loan, a signal of Riyadh's new found dependence on foreign capital, comes as the sustained oil slump encourages other Gulf governments, such as Abu Dhabi, Qatar and Oman, to tap world bond markets./bbl. looking to counter dwindling 

Tuesday, April 5, 2016

The Reserve Bank of India cut its repo rate by 25 bps

The Reserve Bank of India cut its repo rate by 25 basis points to 6.5% overnight, making a widely expected reduction to bring the figure to its lowest in more than five years. But in a surprise move, the RBI also raised the reverse repo by 25 basis points to 6.0%, while taking measures to ensure more availability of cash in the banking system. Heading Down Under: Australia's central bank left interest rates at a record low 2.0%, where they have been for nearly a year, citing evidence of continued growth at home despite an unhelpful rise in the local dollar.

Thursday, March 31, 2016

Dollar continues to weakens on fed dovish statement.

Investors are also tracking moves after the dollar hit a six-week low against the euro, weakening in the wake of recent dovish comments from U.S. Fed Chair Janet Yellen. But it's not just the euro that's making gains against the USD, Asian currencies are also getting a big boost. The Australian and New Zealand dollar are near nine-month peaks, while the Malaysian ringgit has climbed to a new seven-month high against the greenback.

China-led Asian Infrastructure Investment Bank agrees to fund US$500M to India for eco friendlyinvestment projects

India hopes to receive one of the first loans issued by the China-led Asian Infrastructure Investment Bank later this year, as it looks to raise $500M for solar power projects from the newly created lender. The AIIB, which has authorized capital of $100B, plans to join global clean-energy initiatives, and could fund eco-friendly investment projects to avoid allegations of promoting pollution.

Friday, March 4, 2016

Gold prices up 1.2% to $1273.60 per ounce

Gold prices are heading higher, up 1.2% to $1,273.60 per ounce, after closing at their highest level in more than a year on Thursday. Where's the next stop for the yellow metal? Bulls may aim for the January 2015 high of $1,307. Above that level, there is not much obvious resistance until the 200-week moving average, currently at $1,339. Trouble is also a possibility if today's employment report is a strong one, but for now the doves at the Fed have the upper hand.

Wednesday, March 2, 2016

Moody's Investor Service has lowered the outlook on China from stable to negative

Moody's Investors Service has lowered the outlook on China's credit rating from stable to negative, citing a weakening of fiscal metrics and a continuing fall in foreign exchange reserves. "Without credible and efficient reforms, China's GDP growth would slow more markedly as a high debt burden dampens business investment," the ratings agency added. Moody's current Aa3 rating on China is still seven notches above junk, so even if the agency were to follow up on its warning, investors wouldn't have to suddenly start selling the country's bonds. The Shanghai Composite shrugged off the decision along with other Asian shares, climbing 4.3%, after yesterday's record run on Wall Street.

Tuesday, February 23, 2016

Despite the recent gains, Standard & Poor's has downgraded the credit ratings of several Middle East nations, in its second mass cut of large oil producers in almost exactly a year. Citing pressures from the drop in crude prices, the ratings agency lowered Saudi Arabia by two notches to A- stable, and stripped Bahrain of its investment grade status. S&P also cut the ratings of Bahrain and Oman to reflect lower oil price assumptions.

German Business sentiment slid in feburary----mounting fears of slowing growth

German business sentiment fell in February, according to the closely-watched survey by the Ifo Institute, spurring worries that Europe's economic motor is slowing down. The Ifo business climate index showed that morale slid to 105.7 from 107.3 in January, marking the third consecutive month the number has dropped. Germany also confirmed today that its economy expanded 0.3% in the fourth quarter, a rate that could prompt more concerns amid fears about slowing growth.

Wednesday, February 17, 2016

A Power of Attorney executed by the Head Office in favour of the Liaison Office in India does not create a Permanent Establishment if the powers are specific to the liaison office and are not unfettered powers to enable to Liaison Office to act on behalf of the enterprise

Kawasaki Heavy Industries Ltd vs. ACIT (ITAT Mumbai)

The sole basis on which the AO as well as the DRP came to a conclusion that the assessee had a P.E. in India is the clauses in power of attorney executed by the head office in favour of its employee in the L.O. in India. Reliance was also placed on the permission granted by the RBI to the assessee for setting up the L.O. A plain reading of the clauses in the power of attorney takes us to a conclusion that the powers given therein are L.O. specific. The AO’s conclusion that the power of attorney granted unfettered powers to its L.O. employee, to do all or any acts for and on behalf of the assessee, is incorrect. In our view the finding of the AO that the power of attorney is an open ended document, which is clearly outside the scope of initial permission granted by the RBI is also perverse. No doubt the AO can investigate, call for evidences and come to a conclusion where any income earning activity has been carried out by the L.O. so as to construe it as fixed P.E. but, in our view it is beyond the jurisdiction of the AO to adjudicate and conclude that the assessee has filed false declarations before the RBI. At best, he can bring his findings to the notice of the RBI which may consider the same in accordance with law. The RBI has not found any violation of conditions laid down by it while permitting the assessee to have an L.O. In such circumstances, no adverse inference can be drawn

Monday, February 1, 2016

China's official factory activity (PMI index) shrank to three year low in January

China's official factory activity skidded to a three-year low in January, adding to further gloom about the state of the world's second-largest economy. The official Purchasing Managers' Index stood at 49.4, compared with the previous month's reading of 49.7, deepening the case for near-term stimulus and marking the sixth consecutive month of factory activity contraction. The mood was worsened by a private survey from Markit/Caixin that showed January manufacturing activity shrinking for the eleventh straight month.

Wednesday, January 27, 2016

Transfer of shares of an Indian Co by a Mauritius entity to a Singapore entity due to group reorganization is not a scheme for avoidance of tax. The capital gains are exempt under India-Mauritius DTAA. Treaty shopping is permissible. A ROI u/s 139(1) need not be filed if income is exempt from tax

In Re Dow AgroSciences Agricultural Products Ltd (AAR)

 Dow IMEA Group was dismantled in 2010 and that is how the need for realignment of the group arose whereby DAS entity was to be shifted from an entity which falls under Europe region to an entity which would fall in the Asia-Pacific region. This was to be done with a view to achieve better control. Singapore is one of the upcoming countries in Asia-Pacific region in the opinion of the applicant and therefore, the Dow group contemplated to shift the share holding of DAS India from Mauritius to Singapore. All this exercise is also more than 5 years old from the date of the last acquisition of the shares. Thus, it cannot be said that the proposed transfer of shares was amounting to a scheme to avoid payment of taxes in India. It was clearly for the business considerations. We, therefore, reject the contention of the Revenue that this amounting to a scheme to avoid payment of taxes in India. We accept the contention raised by the applicant about its not having a PE in India

Wednesday, January 20, 2016

Weak crude prices weighed on Russian ruble to nosedive to a record low.

The collapse in crude prices also caused the ruble to nosedive to a record low today as the oil plunge weighed on the Russian economy and surpassed every other obstacle the nation has endured including crippling sanctions. The currency fell 1.8% to 80.156 against the dollar, breaching a threshold it last crossed during the ruble crisis of December 2014 that forced the central bank to intervene through a series of emergency rate increases. MICEX -1.6%.

Crude futures falls hitting fresh to its lowest level of 2003

Crude futures are getting slammed again, with U.S. oil falling to its lowest since September 2003 on worries about a global glut. The drop comes after the International Energy Agency, which advises industrialized countries on energy policy, warned on Tuesday that oil markets could "drown in oversupply". Stocks data from the American Petroleum Institute is due later today, while official figures from the Energy Information Administration will be released tomorrow. WTI -2.3% to $27.80/bbl; Brent -2.3% to $28.09/bbl.

Thursday, January 14, 2016

Year 2016 saw $3.2 Trillion wifed off in global stocks

Almost $3.2T has been wiped off global stocks since the start of 2016, driven by renewed jitters over China's economy and a slump in energy prices, pushing all major U.S. indexes into correction or bear market territory. Asian markets (except for China) and European bourses are keeping up the trend today after a bruising session on Wall Street that saw the S&P 500 drop 2.5% and the Nasdaq tank 3.4%. Despite looking for a comeback earlier, U.S. futures have also dipped into the sea of red.

Monday, January 11, 2016

Oil nearly 12 years low on China worries

Oil prices are sharply lower to start off the week as concerns over demand from China impact trading again, along with some fresh worries. Morgan Stanley is the latest major investment firm to forecast oil prices could fall into the $20s with the U.S. dollar continuing to strengthen against major currencies. There is also news that Saudi Arabia is considering an IPO for its state oil company, a development that adds a new layer of anxiety with traders. Brent crude is down 1.42% to $32.69, while WTI crude futures are 1.6% lower at $32.62.

Thursday, January 7, 2016

World Bank cuts growth forecast to 2.9% in 2016

According to the World Bank, the global economy will sputter along this year as China's slowdown prolongs a commodity slump and contractions endure in Brazil and Russia. As a result, the international institution cut its forecasts for the third straight year, predicting 2016 growth to fall by 0.4 percentage point to 2.9%. With regards to the U.S., the World Bank decreased its 2016 prospects to 2.7%, down from 2.8 percent from June, citing the dampening effect on exports from the surging dollar.

Monday, January 4, 2016

Eurozone PMI edged up in november

Manufacturing in the eurozone accelerated at the fastest pace in 20 months in December, with every country clocking in output growth and job creation (even Greece!). Markit's eurozone manufacturing PMI edged up to 53.2 from 53.1 in November, as the ECB's unprecedented stimulus reached companies and households.

Sharp sell off seen on the first trading day of 2016

Fresh manufacturing surveys revived concerns about Beijing's economic slowdown, triggering market declines so steep that authorities had to halt trading there for the rest of the day. The country's activity contracted for the 10th straight month in December - the official manufacturing PMI stood at 49.7 in December, while the Caixin manufacturing PMI fell to 48.2, both below the 50 level that indicates contract -ion The yuan, which begins new extended trading hours today, also hit its lowest point in more than four years in both onshore and offshore trade.

 World shares sold off sharply on the first trading day of 2016, as weak manufacturing data from China and a flare up in tensions between Saudi Arabia and Iran sent traders scurrying from stocks into safe haven assets. The plunge could likely silence any possible "January effect," which usually sees equities that were sold off in December for year-end tax harvesting rally over the next month as investors scoop them back up at lower prices.