The Manipulation of History Essay Example for Free

The Manipulation of History Essay By looking at the past we are presented with conditions of possibility which makes the past constitutive of the present. Such an act involves the individual’s consideration of culture’s role in the authentication of specific memories. Memories emerge spontaneously from people’s stories about their nations. Culture, on the other hand, chooses specific stories which it legitimizes with objectivity by attaching to it the term history. Story lines emerge continually from man’s consciousness however culture with its demands for social order and progress denounces the memories of common people and relegates the task of remembering to the institutions within the public sphere. Such an act leads to the repression and later on the elimination of the peoples desires to tell their own stories. Due to culture’s capability to make memories dissipate from people’s minds while reimbursing it with its own notions of truth, people tend to forget that the accounts of the events given to them may not necessarily be the truth rather they are just one of the several accounts of an event. This shows culture’s power to control the circulation and exchange of ideas society. Furthermore, this shows us that â€Å"truth is a thing of this world†¦produced by multiple forms of constraint and regular effects of power† (Schmidt and Warenberg 288). Historiography, in this sense, only presents us with events which are in accordance with the ideology of the group who is in power. Within this perspective it is interesting to consider how this is apparent in the works discussing a particular event in history. In line with this, this paper’s task is two-fold. First, it aims to present the different accounts regarding a particular historical event. Second, it aims to present an analysis of how these accounts provide an interpretation of an event which manifests the perspective of the individual who discusses the event.   For the sake of brevity, the focus of the paper will be on the Nanjing Massacre as it is presented and interpreted by Iris Chang in The Rape of Nanking and Honda Katsuichi in The Nanjing Massacre. The event known as the 1937-1938 Nanjing Massacre became one of the most reported events by both the Western and Chinese press during the war as it became a major case at the military tribunals in Tokyo and Nanjing after Japan’s surrender. At the end of both trials, the verdict for both the Tokyo trial and the Nanjing trial was the same. The tribunal led to the execution of five Japanese officers who were found guilty for either participating in the said massacre or failing to apprehend the said massacre. The difference between both trials merely lies in the death toll recorded in the former trial. The Tokyo trial of the Nanjing Massacre claims that the aforementioned verdict stands as a result of the occurrence of organized murder, random killings and rape, looting and destruction of the Japanese troops in Nanjing during a six week period on the Winter of 1937-1938 which led to the death of over 200,000 Chinese civilians and prisoners of war as well as the occurrence of 20,000 cases of rape (Pritchard and Zaide 49604-08). The Nanjing trial claims the same things however it states that as opposed to the 200,000 death toll specified in the Japan trial, the death toll reached 300,000 (Second 603-12). In the years that followed the Nanjing Massacre, the information specified on both trials became the springboard for the construction of accounts that presented claims and counter-claims regarding the Nanjing Massacre. Different accounts have circulated regarding the event wherein some accounts affirm the occurrence of the said event whereas others deny its occurrence. One of the most recognized accounts that affirm the occurrence of the Nanjing Massacre is Iris Chang’s The Rape of Nanjing. Iris Chang (1997), an American journalist of Chinese ancestry, wrote the first non-fiction account in a Western language of the Nanjing Massacre in her book The Rape of Nanjing. Within the text, Chang claims that the Nanjing Massacre stands as the East’s equivalent of the West’s Holocaust of the Jews in Europe as both events represent the most heinous cases of violence in recorded history. Chang’s subtitle The Forgotten Holocaust of World War II emphasizes this claim in the aforementioned text. In the introduction of the text, she states, Just as Hitler’s Germany would do half a decade later, Japan used a highly developed military machine and a master-race mentality to set about establishing its right to rule its neighbors†¦marked by countless incidents of almost indescribable ruthlessness†¦ One event can be held up as an example of the unmitigated evil lying just below the surface of unbridled military adventurism, that moment is the Rape of Nanking. (Chang 3-4) As can be seen above, the beginning of Chang’s text may be seen to present the reader with a fixed moral judgment regarding the events that occurred in Nanjing. This moral judgment considers the event in Nanjing as an act of evil. It is important to note however that although, a moral judgment has already been specified in the initial part of the text, Chang clarifies in the later part of the book’s introduction that this judgment does not necessarily aim to establish â€Å"a quantitative record to qualify the event as one of the great evil deeds of history, but (it aims) to understand the event so that lessons can be learned and warnings sounded† (5). The lesson which Chang hopes to be learned from her work refers to the necessity to prevent a â€Å"deliberate attempt†¦to distort history† which she perceives to be evident in Japan’s refusal to recognize the Nanjing Massacre (13). In addition to this, Chang perceives her book as her â€Å"attempt to rescue (the) victims from the degradation by Japanese revisionists and to provide†¦ (her) own epitaph for the hundreds upon thousands of unmarked graves in Nanking† (220). As a text classified within the non-fiction genre, the significance of Chang’s work lies in its presentation of the events in Nanking through the accounts of those who experienced and survived the Nanjing Massacre. It is important to note that Chang was a granddaughter of one of those individuals who escaped Nanjing as Japanese soldiers arrived in the land. Chan’s family thereby stands as one of those who were directly affected by the war since it has forced them not only to leave their homeland but to create new roots in the United States. Within this context, one may argue that Chang’s interpretation of the event may be seen as a result of her attempt not only to remind individuals of the effects of instances wherein they are freed from moral restraints but also as her attempt to recapture her roots and her history. It within this context, that one may understand Chang’s comparison of the Nanjing Massacre to the Holocaust of the Jews. Chang’s comparison of the Nanjing Massacre to the Holocaust of the Jews may seem farfetched since the death toll as well as the duration of the Nanjing Massacre is miniscule in comparison to that of the Holocaust however the comparison may be significant in terms of the politicization or the symbolic use of both the Nanjing Massacre and the Holocaust by its perpetrators since both events served as a symbol of the brutal character of their perpetrators in such a way that the Nanjing Massacre served to symbolize the military aggression of the Japanese army during that time. Chang’s aforementioned text has been continuously questioned. The Japanese publishing company, Kashiwashobo Publishing Company, for example, considers the text to be â€Å"based on prejudice and misconceptions (as a result of) its author’s basic attitude† (1). In the 20 May 1999 press release given by the Kashiwobo Press after its cancellation of the Japanese version of Iris Chang’s The Rape of Nanking, Kashiwashobo Press states, We must provide good history books on the War in order to learn from the past and to avoid the same kind of tragedies in the future. But this publisher also believes that we are responsible for publishing qualified books for the good of the public†¦The fundamental cause of the termination of the contract is the original work, which†¦due to its errors and inaccuracies, The Rape of Nanking has contributed to reviving deniers of the Nanking atrocities in Japan by giving them bullets to challenge the historical event. (1-2) One of the errors of Chang’s text lies in stating that there are no Japanese texts which have recognized the occurrence of the Nanjing Massacre. Such texts however exist. One of these texts which was published prior to the publication of Chang’s text is Honda Katsuichi’s The Nanjing Massacre. In the introduction of the Honda Katsuichi’s The Nanjing Massacre, Katsuichi’s states, I wrote this book not as a means of apologizing to China but as a means of revealing the truth to the Japanese people. Having been a child at the time, I bear no responsibility for the actual massacre, but as a Japanese journalist, I bear some responsibility for leaving the story unreported for such a long time†¦I hope that that the mere fact of my reportage being widely read overseas will serve as gaiatsu and will bring about a change in the disgraceful anti-internationalist behavior of the Japanese government and the conservative forces. (xxvi-vii) From the very beginning of the text, one sees a difference between Katsuichi’s approach to the Nanjing massacre as opposed to Chang’s approach to the said event. Although both individuals are journalists and both of their works do not use sophisticated methodology in order to support their accounts within their texts, one notes that Katsuichi’s goal is for the redemption of the Japanese people. As the subtitle of the work states, Katsuichi’s text aims to ‘confront Japan’s national shame’. This shame may be seen to be a result of the following factors: (1) The Japanese government’s refusal to recognize the Nanjing Massacre and (2) The Japanese people’s inability to recognize the veracity of this event as a result of the Japanese government’s refusal to recognize the aforementioned event. For Katsuichi, retelling the event may enable the enlightenment of the Japanese people which may further enable the Japanese peoples’ recognition of the necessity to change the framework of their government. Katsuichi’s aim in retelling the events of the Nanjing Massacre is for the occurrence of an ideological revolution within the country. Such an aim was supported by his factual reportage of the events within his work. Within Katsuichi’s The Nanjing Massacre, for example, one notes that the Japanese atrocities would not have been prevented even if the Chinese surrendered peacefully since the Japanese troops were already committing atrocious acts along their way to Nanjing. In addition to this, one notes that the Japanese did not find the act of murdering Chinese as an immoral act since they have long considered the Chinese to be inferior entities. Furthermore, as the book progresses, one also notes that the Japanese did not recognize the regulations set within the International Safety Zone as the Safety Zone was continuously entered by the Japanese troops. Katsuichi’s text, in this sense, affirmed the occurrence of the Nanjing Massacre. What makes his text and his account distinct from Chang’s is the perspective from which he perceives the event. One may state that Chang’s highly graphic portrayal of the events in Nanjing as well as her misguided notion that the Japanese failed to present an account of the event may be seen as a result of her position as a victim of the Nanjing Massacre. As was stated in the aforementioned discussion, Chang’s family stands as a survivor of the Nanjing Massacre. As opposed to this, Katsuichi’s more objective portrayal of the evident may be seen as a result of his position an heir to the Japanese people who have committed the aforementioned evident. Within this context, one may state that an author or speakers interpretation of a historical event is affected by his position in relation to the occurrence of the event. If the author or speaker stands in line with the perpetrators of the event, he may either present an account which aims to defend the people who committed the atrocities or he may present an account which aims to sanctify the people who committed those atrocities or to sanctify the succeeding generations affected by the stain of those who committed atrocious actions. If however the author or speaker stands in line with the victims of the event, he may either present an account which aims to commemorate the victims or he may present an account which aims to further vilify the perpetrators of the crime. Given these two accounts of an event from two different perspectives, the goal of the reader does not merely lie in considering whether an account presents the truth or not but to consider that as history is necessarily a nihilation and hence one cannot accurately determine one account as to comprise the totality of what transpired, hence the purpose of a supposed event is to be open to interpretations. Works Cited Chang, Iris. The Rape of Nanking: The Forgotten Holocaust of World War II.   New York: Penguin Books, 1998. Gibney, Frank, ed. â€Å"Editor’s Introduction.† The Nanjing Massacre: A Japanese Journalist Confronts Japan’s National Shame.   By Honda Katsuichi. Trans. Karen Sandness. New York: East Gate Book, 1999. Kashiwashobo Press. Kashiwashobo Press Release about the Cancellation of the Japanese Version of Iris Chang’s The Rape of Nanking. 20 May 1999. Katsuichi, Honda. The Nanjing Massacre: A Japanese Journalist Confronts Japan’s National Shame.   Ed. Frank Gibney. Trans. Karen Sandness. New York: East Gate Book, 1999. Pritchard, John and Sonia Zaide, eds. International Military Tribunal for the Far East: Tokyo War Crimes Trial. 22 vols. New York: Edwin Mellen P., 1998. Schmidt, James and Thomas Warenberg. â€Å"Foucault’s Enlightenment: Critique, Revolution, and the Fashion of the Self.† Critique and Power: Recasting the Foucault/Habermas Debate. Cambridge: MIT P., 1994. Second Archives of China et, al. Archival Materials on the Nanjing Massacre by the Invading Japanese Troops. Nanjing: Np, 1987.

Macbeth Essay Example for Free

Macbeth Essay Since the Mesopotamian era of 3000 B. C. numbers have been an essential part of life and are easily found throughout society, imbedded in religion, intertwined in mythology and commonly related with superstitions. Even in the twenty-first century people still believe in ancient numerical superstitions, such as the lucky number seven, or the unlucky number thirteen. During the seventeenth century William Shakespeare uses societal superstitions in his famous tragedy, â€Å"Macbeth†, by writing in a threefold literary pattern. Shakespeare reinvents the number three by relating in to evil and darkness throughout the play, providing it with a new superstitious meaning. â€Å"Macbeth† follows the transformation of the title character from thane to king, sane to evil. After putting down two rebellions against the King of Scotland, Macbeth is awarded title and favor with the gracious King Duncan. When greeted by three mysterious witches, they prophesy that Macbeth will be made Thane of Cawdor and eventually King of Scotland. They also prophesize that Banquo will beget a long line of Scottish kings but will never be king himself. Macbeth and Banquo treat their prophecies sceptically until some of King Duncan’s men come to thank the two generals for their victories in battle and to tell Macbeth that he has indeed been named thane of Cawdor. In attempt to aid the prophecy, Macbeth murders the good Duncan and is crowned King of Scotland, but once his great goal to be king is achieved he begins to fear the prophecy brought forth to Banquo. In fear of being overthrown from the throne Macbeth goes on a psychotic rampage attempting to protect his future while ruining his sanity and brings upon himself his own demise. While entangling the threefold literary pattern into a tragic plot, William Shakespeare presents the appearance of three apparitions, the three murders, and the character choice of three witches to precipitate evil at the presence of the number three. Shakespeare turns the conventional and traditional meaning of three’s upside down in act one, scene one when he begins to relate the number to evil. Threes are commonly related to stability and completeness; in religion there is God omniscient, omnipresent and omnipotent, in time there are three divisions, past, present and future, and three grammatical persons- me, myself and I. In a dark and ominous meeting, Shakespeare introduces his audience to three women who will continue to haunt Macbeth throughout the play: the three weird sisters. As the first characters the audience has the pleasure of meeting, the witches set the mood for the entire play with a sense supernatural as â€Å"instruments of darkness† (I. iii. 136). In the opening scene of the play each witch speaks three times within the first eleven lines, the first two being â€Å"When shall we three meet again / In thunder, lightning, or in rain? coupling three undesirable and threatening circumstances, suggesting constrictions and limitations as these three things generally happen at the same time. The triplet pattern begins with this, giving a false sense of stability until to the audience until the witches state that what is â€Å"fair is foul, and foul is fair† (I. i. 12). This suggests that the stability of threes is actually a farce and will bring instability and chaos. Before t heir meeting with Macbeth, the fist witch informs her sisters that she has planned revenge against a sailor whose wife refused to share her chestnuts. Through her description of her plan, Shakespeare reveals to his audience that they posses great power but with limits unlike an instrument of fate would have. She plans to transport through a â€Å"sieve† (I. iii. 9) to curse him but she is not powerful enough to have him shipwrecked, only to have his ship â€Å"tempest-tossed† (I. iii. 26), showing their limits. As the first witch explains her plan she speaks in triplets, â€Å"I’ll do, I’ll do, and I’ll do† (I. iii. 11), to emphasize her evil intentions. When Macbeth and Banquo present themselves to the witches just moments later, they greet Macbeth â€Å"All hail, Macbeth! Hail to thee, Thane of Glamis! / All hail, Macbeth! Hail to thee, Thane of Cawdor! / All hail, Macbeth, thou shalt be king hereafter! † (I. iii. 51-53). Three greetings that seem so fair â€Å"of noble having and of royal hope† (I. iii. 59) are sure to turn foul. The greetings mimic the common greeting of the New Testament, â€Å"All Hail† (Matthew 28. 9). In Matthew 26. 49, Judas prepares to betray Jesus to the Sanhedrin and Roman soldiers. His plan is to identify Jesus by greeting him with a kiss so that the soldiers will know which man to arrest. Judas approaches Jesus, saying, Hail Master. The witches greet Macbeth in a similar fashion, and, as Judas betrayed Jesus, so do the witches betray Macbeth. This mirroring comparison shows Shakespeare cutting all biblical and holy beliefs in the number three, using religious evidence to eliminate the idea that three is a number of stability. Shakespeare even has his three witches speak in contradictions to create moral confusion and increase the presence of evil, such as when the witches characterize Banquo as â€Å"lesser than Macbeth, and greater† (I. iii. 68). After stirring up quite a bit of trouble, the witches vanquish, not to be seen again until the first scene of the fourth act. The signal to begin their evil incantations is brought to the witches by three meows of a â€Å"brinded cat† (IV. i. 1). Again, the witches take turns, speaking in a threefold pattern, taking their turns and presenting a rhyming, triple statement to open the act; â€Å"Thrice the brinded cat hath mewd. / Thrice, and once the hedge-pig whined. / Harpier cries â€Å"‘Tis time, ‘tis time† (IV. i. 1-3). While working on concocting brew the witches chant around a cauldron, throwing in various items, taking turns to add their contributions, dividing the ingredients into three separate groups. When Macbeth arrives to the cavern he greets the witches as â€Å"secret, black, and midnight hags† (IV. i. 48), three negative descriptions dripping with evil connotations. The â€Å"weird sisters† (III. iv. 165) conclude the evil presence within triplet patterns by presenting three mysterious visions or apparitions to Macbeth, in order to provide him with the same sense of false security that the audience had felt initially. With thunder roaring in the background, Shakespeare thrusts his main character into various situations that would terrify any person â€Å"milk of human kindness† (I. v. 7). When Macbeth is faced with the three apparitions they bring him fair sounding news that is doomed to be destructive and â€Å"foul† (IV. iii. 28) because of the threefold predictable pattern. When the first of the three mystical spirits appears to Macbeth in the form of a floating warhead, warning him to â€Å"beware Macduff† (IV. i. 81), Macbeth shrugs it off, already knowing this. When the second apparition appears as a bloody child, it tells Macbeth that no man born of a woman can do him harm. This gives Macbeth great confidence: Then live Macduff: what need I fear of thee (IV. . 93). Finally, the third ghost appears as a child wearing a crown with holding a tree in hand. This phantom is the one to stir Macbeth’s blood and spook him and has him demanding to know the meaning of the final vision. The child tells Macbeth that he â€Å"shall never be vanquished [†¦] until/ Great Birnam Wood [comes] to high Dunsinane Hill† (IV. i. 105-106), a seemingly impossible task, but in the Shakespearean world of three’s, things are not as they seem. This, giving Macbeth false security, is followed by a procession of eight crowned kings all similar to the one before. The final king carries a mirror, showing a seemingly endless lineage of kings, frightening Macbeth into overbold, unthinking irrationality, contrary to his previous semi-thoughtful behaviour. The three apparitions all in still a false sense of self-assurance in Macbeth but after Shakespeare’s triplet patterns have caused nothing but grief during the play, the audience is able to see through the prophetic ghouls that act as symbols, foreshadowing the way the prophecies will be fulfilled. The warhead suggests a third rebellion, the first two put down by Macbeth while the third is caused by his treacherous ways in a turn of events that can only suggest that if Macbeth hasn’t died the first two times, then the third time’s the charm. The bloody child of the second vision is the image of Macduff as a babe â€Å"from his mother’s womb / untimely rippd† (V. viii. 19-20), delivered through caesarean section. This minor technicality that evades Macbeth is the key to his downfall, and thanks to his ignorance he believes he is invincible. The line of kings, thrust in Macbeth’s face is his last hope, the finishing blow. With the knowledge that there will be men who â€Å"are too like the spirit of Banquo† (IV. i. 127) Macbeth subconsciously knows that all hope is lost to him, but he clings to the second apparitions speech, claiming that he cannot be harmed by any person born of a woman. The terrible three’s that Shakespeare entangles into the apparition’s doom-filled messages not only anticipate the death of Macbeth, but also lead him to it. It is by his self-assurance, pride and ambition that Macbeth believes he will survive, hearing only what he wishes from the prophecies. Since the prophecies suggest he will be fine, Macbeth takes it to heart and believes so without watching out for himself; he does not attempt to prevent the rebellion, nor does he stay in the castle when he knows he is a target because â€Å"none of woman born [can] harm Macbeth† (IV. i. 91-92). By presenting these ghoulish visions, the witches lead Macbeth to his death by power of suggestion and lack of a complete digestion of the situation on the title characters part. The witches’ prophetic ways also lead Macbeth to far worse things than pride. Macbeth is urged by the third prophecy of being king to kill Duncan, King of Scotland. Although his wife is the â€Å"spur† (I. vi. 25) who pricks the horse of intent, the intent is spawn from the prospect of his hopes coming true. The third prophecy leads him to murder, using trickery to make the fair prospect of being King derive from such a foul act as unjust murder against the â€Å"gracious Duncan† (III. vi. 3-4). If Macbeth had stayed content with the first murder he could have lived a happier life, but troubled by the prophecy presented to Banquo, Macbeth fears for his throne and sets out to murder his best friend in a foolish attempt to disprove the prophecy. Macbeth performs his second murder. While this time, instead of doing it himself, Macbeth hires two murders, but as the fates have it a third joins the informal party. With the third murderer present, a seemingly easy kill has become a challenge and struggle because three is a crowd. If the third murderer was Macbeth, unable to stay away from the murder of his self-sworn enemy, it is no doubt that he tagged along to fulfill the destruction of a prophecy, only intensifying its after effects. Macbeth becomes miserable and his mind is unclear; the second murder had haunted him and caused him great fear. If not for the prophecies and initial trickery, Macbeth would have not stopped to rage against a friend that had been so dear to him and would have not killed Banquo in an attempt to save his own life, that was previously not in danger. The first two murders written by Shakespeare mainly show cause, but the third and final brings a big effect. With Macbeth murdering the innocent wife and children of Macduff, just because he fears Macduff knows the truth about Duncan’s murderer, the intent of murder changes. The first two were intended to attain and keep a powerful position, but when his pride and fear get the better of him, Macbeth hires men to commit the third murder with no sense of regret, as he had after murdering Duncan (â€Å"I am afraid to think what I have done† (II. ii. 66)). Nor is Macbeth mentally disturbed, as he had been after murdering Banquo, seeing ghosts. After the third murder, Macbeth is a well-seasoned professional and becomes emotionally detached from his victims as they become but another dead. The third murder backfires and works against Macbeth, only spurring the intent of Macduff to slaughter him more savagely than before. Shakespeare pushes the idea that there needs to be a third murder in order for symmetry and regulation, but by adding in a third murder, Shakespeare is able to, again, shatter all former pretences about the stability of the number three, changing its relationship to represent evil. While using triplet speaking patterns, triplet events and groups of three people, Shakespeare uses three savage murders, three frightening apparitions and three ugly, diabolical and manipulative witches to present the number three as a superstition, dragging along evil wherever it goes. While Shakespeare uses the number three to predict and present evil throughout the tragedy â€Å"Macbeth†, he strives toward changing societal views of the number. With a simple beheading, Macbeth’s tragic downfall is complete and caused entirely by the three prophecies foretold by the three witches who showed Macbeth the three apparitions and encouraged him to commit three murders. By introducing the three witches first, Shakespeare relates the number three to the hags immediately and through their chaotic destruction of people’s lives by influencing their sins, the witches represent all the evil of the prophecy.

Factors That Affect the Market Price of Oil

Factors That Affect the Market Price of Oil THE FACTORS THAT AFFECT THE MARKET PRICE OF A PRODUCT SUCH AS THE WORLD PRICE OF OIL IN THE PAST TWO DECADES. BRIEF: 103737 INTRODUCTION In order to have a good understanding of the factors that affect the market price of a product, one will first need to grasp the meaning of what a market is. A market can be defined as an area over which buyers and sellers negotiate the exchange of some product or related group of products. It must be possible, therefore, for buyers and sellers to communicate with each other and to make meaningful deals over the whole market. Individual markets differ in the degree of competition among the various buyers and sellers. In some cases where the number of buyers and sellers is sufficiently large no one of them will have any appreciable influence on price. This is what is known as a perfectly competitive market. However, for the purposes of this essay we will stick to the concept of a market. Using the table below we will show how the market price of a product (bread) is affected. Demand and supply schedules for eggs and equilibrium price From the table above we can see that the quantity demanded is much higher than the quantity supplied at 110 and 5 and the price is  £0.50. This shows an excess demand of 105. When the quantity demanded is 90 and the amount supplied to the market is 46, we have excess demand of 44 we correspondingly have a market price of 1. However, when the quantity demanded is 77.5 and the quantity supplied is 77.5, the market price for bread is  £1.50. At this point the quantity demanded is the same as the quantity supplied. At such a price consumers wish to buy exactly the same amounts as the producers wish to sell, this is known as the equilibrium price. At prices above  £1.50 the quantity supplied exceeds quantity demanded. Furthermore, the higher the price, the lower the excess of quantity demanded over quantity supplied. The amount by which the quantity demanded exceeds the quantity supplied is called the excess demand, which is defined as quantity demanded minus quantity supplied (qd à ¢â‚¬â€œ qs). This is shown in the last column of the table. Finally, consider prices higher than  £1.50. At these prices consumers wish to buy less than producers wish to sell. Thus, quantity supplied exceeds quantity demanded. Furthermore, the higher the price, the larger the excess of one over the other. In this case there is negative excess demand (qd – qs Now that we have understood the factors that affect the market price of a product, we can now move on to talk about the factors that affect the fluctuations in the price of oil for the past two decades. In 1985, the price of oil (Saudi Arabian Light) was $27.53 per barrel[1] (yearly average). The price of oil during this period was falling, in which in 1986, the Saudi’s abandoned the swing producer role because they had the largest reserves of oil and capacity utilization to stabilize the price of oil when there was a shortage in the world oil market. By 1987, the price of oil had dropped to $16.95. In 1988, it dropped further to $13.27 and $15.62 in 1989. In 1990, Iraq invaded Kuwait in what turned out to be a huge blow to the stable price of oil. The oil price rose to $20.45 per barrel. The major reason for this is that both Iraq and Kuwait were members of OPEC and due to the war there was a shortage of oil in the world oil market which led to an increase in the price of oil. Between 1990 and 1991 America launched operation desert storm, which was to help Kuwait against Iraq. This also contributed to the rise in the price of oil as America is the largest consumer of oil, an d they needed it during the military campaign of operation desert storm. In 1991 and 1992, the price of oil decreased to $16.63 and $17.16 respectively. In 1993, it fell again to $14.95 and $14.74 in 1994. In 1995, the price rose to $16.10, and in 1996 it shot up to $18.52. In 1998, the price initially dropped to $12.21 but shot back up again to $17.25 in 1999. The main reason for this during this period was that there was an Asian economic crisis; the Iraq oil-for-food programme which helped in stabilizing the price of oil in 1998. In 2000, the price of oil leaped to an astounding $26.20. The reason for this was that due to the decline in the price of oil OPEC members decided to cut back production in order to stabilize the price of oil, before it went below the amount various member countries of OPEC will be able to cover the cost of producing oil. In 2001, the price decreased to $22.81, and in the same year (Sept. 11th) there was an attack in the US which destroyed the world trad e centre. In 2002 to 2003, the price of oil rose to $23.74, and $26.78 respectively. This came about due to strong demand growth mainly from countries like China, and India, in which in 2004, the price of oil jumped to an ecstatic $33.64. In the present year of 2005, the monthly average of the price of oil has reached $63 a barrel. However, for reasons to do with accuracy, we have decided not to use 2005 figures since we are still in the year. The following graph represents the trend in the world price of oil over the past two decades. Data source: BP Statistical Review of World Energy, June 2005. On the supply side, the main players in the crude oil market are OPEC, which currently provides about 40 percent of world supply and hold about 70 percent of proven oil reserves, and non-OPEC producers who own the rest. OPEC as the marginal supplier does act like a cartel in most cases, i.e. they collude to restrict the output of oil and raise the price far above their cost. In recent years, its policy has been to balance the market while allowing for an appropriate level of crude oil inventories in consuming nations. Non-OPEC producers, on the other hand, have relatively limited reserves and spare capacity, and generally behave as price takers. Currently, the estimated reserves of OPEC are 890 billion barrels, as opposed to 177 million barrels for non-OPEC members. In the latter years, world events such as the Iran and Iraq war, the Asian economic crisis, the invasion of Kuwait by Iraq, and corporate social responsibility such as country legislation which regard environmental pollut ion as high on the agenda (in some country’s environmental pollution is stricter than others in order to produce oil, e.g. Nigeria has a less stricter environmental pollution legislation compared to Saudi Arabia) have all contributed to the fluctuations in the world price of oil. However, of recent, the strong demand growth from Asia and China in particular can be said to be the reason why the price of oil is rising. The consumption of oil in 2004 grew by 2.9 million barrels a day (mbd) (3.7 percent of which China contributed about 1 mbd) relative to 2003, which can be said to be the largest increase in the past 20 years. With notable exceptions of Iraq, Russia, and Saudi Arabia, the world’s oil producers may be close to their short-run output capacity. Thereby, continuing increases in demand and the possibility of even minor disruptions (Hurricane Katrina (US), Industrial disputes (Nigeria), environmental concerns (Nigeria)) in supply thus help in explaining the high market price for oil. Investment in refining capacity has been too low, and a mismatch has emerged between the type of refining capacity now required and what is available. For sometime, world oil demand has been driven by high-quality light crude (oil of low density or containing a low wax content, which makes production and refining easier) and by sweet crude (oil with a low sulphur content). Recent additions to production capacity by OPEC have though largely been in the heavy and sour grades of crude, which are more difficult and costly to refine. This lack of investment in appropriate refining capacity and limited substitution possibilities has pushed the retail price of oil up. Another reason which can be said to this lack of investment by OPEC members is a price collapse. When demand falls and the quotas allocated to member OPEC countries breaks down, the price can drop dramatically. For example, in 1997, OPEC raised its production ceiling by 2.5 million barrels per day in ant icipation of growing Asian demand, but the currency crisis of late 1997 instead caused Asian demand to fall. The result was a market price in 1998 that dipped to as low as $12.21 per barrel, the lowest level since 1973, and a $51 billion year over year reduction in oil revenue. In addition given continued uncertainty over the pace of China’s economic development, OPEC may be cautious in expanding supply capabilities due to this. This uncertainty of slow or minimal investment contributes to high futures prices for oil delivery several years ahead. One should also note that since 1986, most oil exporting countries have been burning more oil than they have discovered and since 1998, there has been a fragile balance between supply and demand. Oil is being found at a lower rate than what has been consumed, i.e. we are finding reserves at 7 billion while consuming oil at 30 billion barrels per annum (Exxon-Mobil estimates), hence the law of price adjustment and equilibrium can be s aid to have taken place. SUMMARY AND CONCLUSION This paper has looked at the definition of what a market is. We have also mentioned the concepts of demand and supply with regards to equilibrium and the law of price adjustment. The erratic movement in the price of oil in the past two decades are also looked at. Issues of what factors cause fluctuations in the price of oil such as, the lack of investment by various OPEC member countries into oil production so as to keep up with the world demand of oil, the increasing demand of oil from Asia and the Peoples Republic of China, and the uncertainty of the oil market are all mentioned. It will be worthwhile to conclude that although at present these factors seem to be the norm that affects the price of oil, one should be more cautious into the future, as with hindsight these factors could become obsolete with time passing by. Potential factors which could turn out to be embedded in the future range from alternative sources of energy to synthetic fuels, in which in the long term the demand of oil will continue to exceed supply until the previous mentioned becomes entrenched in most economies. BIBLIOGRAPHY Asian Development Outlook, (2005), The challenge of higher oil prices. BP Statistical Review of World Energy, (2005), Putting energy in the spotlight. Berkmen, P., Ouliaris, S., and Samiei, H., (2005), The structure of the oil market and causes of high prices, research department, International Monetary Fund. Chrystal, K.A., and Lipsey, R.G., (2004), Economics, Tenth Edition, Oxford printing press. International Energy Agency, (2004), Analysis of the impact of high oil prices on the Global economy. www.iea.org/textbase/papers/2004/high_oil_prices.pdf. International Monetary Agency, (2004), Analysis of the impact of high oil prices on the global economy, research department, December. Saxton, J., (2005), Explaining the high price of oil, Joint Economic Committee, Research Report, United States Congress. Serrapere, J., (2005), Crude Oil – Energy and Market Outlook, September. APPENDICES Source: BP Statistical review data 2005 The following table since 1999 shows that there has been no ‘Real’ excess oil supply. Estimated Annual World Oil Demand Growth 2000 – 2005 (million barrels daily) % Change Source: IEA monthly oil report July, 2005. 1 Footnotes [1] The reason we have used US dollars is that it is predominantly used internationally as the currency to benchmark trade.

The Impact of Eleanor Roosevelt as First Lady Essay -- biographies bio

The Impact of Eleanor Roosevelt as a First Lady   Ã‚  Ã‚  Ã‚  Ã‚  Before Eleanor Roosevelt, the role of the first lady was not a political role; it was merely just a formal title of the president’s wife. Eleanor Roosevelt paved the way for all presidents’ wives to come by being active in politics during and after her husband’s presidency. Of course, she did not have instant success; she had many trials which helped her become an important and influential role model. Eleanor Roosevelt’s dedication to her husband, her activeness in politics, and her volunteer work enabled her to change the role of the First Lady.   Ã‚  Ã‚  Ã‚  Ã‚  Eleanor Roosevelt was born on October 11, 1884 to Elliot and Anna Hall Roosevelt. Her mother was very beautiful and thought of Eleanor as a disappointment and would even make fun of her and call her mean nicknames like â€Å"Granny† (Cook, 21, vol. 1). Her father adored her and she adored him but he was never around due to the fact that he was an alcoholic and a drug addict (Morey, 14). When Eleanor was seven years old, her parents got a divorce; which left her mother, Anna, to raise the children alone (Spangenburg, 4). Eleanor’s parents both died shortly after, her mother when she was eight, and when she was ten she learned that her father had died as well. Eleanor and her two younger brothers were sent to live with their Grandmother Hall (Morey, 16-17).   Ã‚  Ã‚  Ã‚  Ã‚  Although Eleanor did not have a pleasant childhood, things started to look up when she started dating her fifth cousin, Franklin Delano Roosevelt. They were married on March 17, 1905 (Cook, 162, vol. 1). Eleanor’s Godfather, Theodore Roosevelt, the current president, agreed to walk her down the aisle at her wedding (Morey, 25-27). After their wedding, Franklin and Eleanor’s house was still not ready, so they lived with Franklin’s mother, Sara, who was not very fond of Eleanor. Once Eleanor started having children Sara even insisted on helping raise them because she considered herself to be a better mother than Eleanor (Morey, 28). Eleanor gave birth to 6 children, but lost one and from this became depressed. This was a hard time for her especially living with Sara. Finally, in 1910 they moved away from Sara to Albany, New York so Franklin could run for Senator (Cook, 184-186, vol. 1).   Ã‚  Ã‚  Ã‚  Ã‚  Eleanor Roosevelt was dedicated to Franklin and was always helping him out behind the scenes. When Franklin became... ...er own experiences and observations. Eleanor also said, â€Å"I had really only three assets: I was keenly interested, I accepted every challenge and every opportunity to learn more, and I had great energy and self-discipline.† (Spangenburg, 99) Eleanor Roosevelt changed the role of the first lady by her dedication to her husband through everything, her involvement in politics, and her willingness to help others through her volunteer work. Works Cited Black, Allida M. Courage in a Dangerous World. The Political Writings of Eleanor Roosevelt. New York: Coumbia University Press, 1999. Cook, Blanche Wiesen. Eleanor Roosevelt 1884 1993. Vol. 1. New York: Penguin Books Ltd, 1992. Eleanor Roosevelt 1933 1938. Vol. 2. New York: Penguin Books Ltd, 1999. Lash, Joseph P. â€Å"Eleanor Roosevelt.† Encylopedia Americana. 1997 ed. Levy, William Turner, and Cynthia Eagle Russett. The Extraordinary Mrs. R. A Friend Remembers Eleanor Roosevelt. New York: John Wiley and Sons, Inc., 1999. Morey, Eileen. The Importance of Eleanor Roosevelt. San Diego: Lucent Books, Inc., 1998. Spangenburg, Ray, and Diane K. Moser. Eleanor Roosevelt A Passion to Improve. New York: Facts on File, 1997.

The Job that Changed My Life :: Personal Narrative essay about myself

The Job that Changed My Life    My grandfather was a police officer when he was younger; he would tell us stories of he and his buddies on motorcycle patrol and the life of a cop. The stories that he told were so interesting, that ever since, I wanted to have a career in law enforcement. After I graduated from high school, I enrolled in the law enforcement program at Spokane Community College where I planned to fulfill my dream of becoming a cop. I started the law enforcement classes at the college and came to the conclusion that law enforcement was not the career for me.    It takes a special breed of person to be in the law enforcement/corrections field, a person who can withstand the stress and unhealthy surroundings that come with the work. Before you go out and do something that is as drastic and life changing as a career choice, you need to know what your getting your self into, so do your research and make sure that is what you want.    The corrections program was similar to law enforcement, so I switched to the correction alternative because I still wanted to be associated with law enforcement. I was hired on at a juvenile detention center as a juvenile correction officer. I thought that this was my opportunity to do something to help these kids, don't get me wrong I did not think I could help or save the world, I just thought I would or could make a difference in one life that it was all worth the hassle. Well I was wrong, my first day of on the job training we had to restrain a kid who was out of control, it only got worse from there on. It seemed like an everyday occurrence in this place; the kids were ok most of the time, but it only took one kid in a bad mood to set the other 40 kids off then it turns into a big problem.    This job was physically and mentally demanding of my energy. I worked anywhere from ten to thirteen hour days; my stress level sky rocketed, and my school work started to suffer, eventually I dropped out of school because I was miserable at this job; the stress was so high; I had major mood swings, and I did not know what to do.

The tour :: Short Stories Science Medical Essays

The tour Her breath was becoming labored. It was always like this after working a full shift in the zone. The dust made her throat dry and her lungs ache. The feeling of every pore in her body closing in response to the biological assault was all too familiar. She had been on the Tour now for three months; many people did not survive more than two, and she theoretically had to serve five. There wasn't anyone she knew that had actually completed their Tour, except for Xern, and his respiratory system had been replaced at least twice. But now Sweepers were just as expendable as cars used to be -- internal organs could be replaced or even upgraded, but it eventually became more cost effective to generate a new body than to constantly maintain an old one. Besides, the Sweepers did not seem to be of use to anyone, beyond the task they performed. And after working a full shift, they were not even of use to themselves. Sometimes she was so mentally and physically spent that she would barely make it through the evening recalibration before falling asleep -- only to wake up feverish a few hours later. Tonight was no exception. It hurt so much to breathe, let alone cough or yawn. She had trained herself to take short, even breaths, because any sudden or deep intake sent a stabbing sensation throughout her chest. She couldn't even remember the last time she felt healthy. It was certainly sometime before she received that notice on her monitor: The Federal Medical Management and Research Association has identified a particular segment of your DNA that indicates immunity to BH-247XN30. This immunity merits a rarity of 5 on the Milton Scale, and has been identified in only .000014% of the population. Less than 5% of the same have been randomly selected to participate in Tour 598E that begins 1645/28/07/2048†¦ She had only vaguely heard of these Tours up until that point. They were of the vicious rumor variety, much like the perpetual threat of a comet-Earth collision. After she received the notice, she accessed the information site for the Tours. The laws governing them had been implemented 1022/03/05/2045, almost three years earlier. When she checked her voting account, she discovered that she had even submitted her approval for the laws.

Transfer Pricing

Chapter 1 Introduction of the Topic TRANSFER PRICING TRANSFER PRICING is a term used to describe all aspects of inter Company pricing arrangements between related business entities, and commonly applies to inter Company transfers of tangible and intangible property. Inter Company transactions across borders are growing rapidly and are becoming much more complex. Transfer pricing refers to the internal pricing system that is used when divisions in the same firm deliver products or services to each other. The transfer price is a cost for the receiving division and revenue for the supplying division, so it affects the financial result of both divisions involved. Transfer prices can be based on market prices, but for various reasons a market-based transfer price might not be appropriate: transactions taking place between the divisions of the same firm are often unique and would not be offered stand-alone on the market. In practice, therefore, cost-based and negotiated transfer prices are used apart from market-based prices. Transfer pricing, for tax purposes, is the pricing of inter Company transactions that take place between affiliated businesses. The transfer pricing process determines the amount of income that each party earns from that transaction. Taxpayers and the taxing authorities focus exclusively on related-party transactions, which are termed controlled transactions, and have no direct impact on independent-party transactions, which are termed uncontrolled transactions. Transactions, in this context, are determined broadly, and include sales, licensing, leasing, services, and interest In India also, considering the importance of Transfer Pricing, Section 92 of the Income-tax Act, 1961 (‘the Act’) empowered tax authorities to make adjustments to income on arm’s length basis in case of transactions between residents and nonresidents having ‘close connection’. Also, section 40A (2) (a) was introduced in the Statute, giving powers to the assessing officer to disallow the expenditure incurred in respect of which payment is made to related parties, if assessing officer is of the opinion that such expenditure is excessive or unreasonable. However, these sections were limited in scope and had certain inadequacies viz. the term ‘close connection’ was not defined, there were no rules concerning documentation, the burden of proof was on the assessing officer, no rules were prescribed for determining arm’s length prices etc. On the Customs side, under the Customs Valuation (Determination of Price of Imported Goods) Rules, 1988, there were provisions for rejecting the transaction value when the buyer and seller were related persons or when they had interest in one another’s businesses. Corporate the world over are expanding their wings in an effort to gain a share of the global pie. There is talk of the world fast turning into a global village with economies increasingly becoming inter-connected. But with cross-border trade comes a whole new set of problems, Transfer pricing is one of them. When a company opens a branch in another country, gets its products manufactured there and then imports it, there is a question mark over what price should the parent pay for buying the product from the subsidiary. This price till now has been subject to the parent’s discretion and has been used by many corporate the world over to control the tax outgo to their Government. In effect, the price at which goods are transferred from one arm of the company to another is known as transfer pricing. The Finance Act 2001 introduced the detailed Transfer Pricing Regulations (T. P. R. ) in India from 1stApril 2001 APPROACHES TO TRANSFER PRICING Taxation that is based on transfer pricing is becoming an important issue for many companies, whether U. S. based or foreign based. The regulations have sought to impose extensive general principles and guidelines that apply when the taxpayer selects the transfer pricing method. These methods impose penalties on an inappropriate choice of a transfer pricing method. In addition, the administrative cost of complying with the regulations can be extensive. As a result, implementation of the transfer pricing regulations may impose significant costs on the taxpayer above and beyond the taxes themselves. Faced with this transfer pricing onslaught, businesses have chosen different approaches to the tax aspects of transfer pricing. At the outset, the selection of a transfer pricing strategy is determined by three factors: 1. Taxes imposed on the transfer pricing decision 2. Administrative time and expense incurred 3. Potential penalties (which are discussed next) Over the past decades, the topic of ‘transfer pricing’ has continuously attracted attention in the literature. The reasons for this intensive degree of attention are diverse. Lots of managers, in particular CFOs and controllers, can elaborate on the number of hours spent in order to reach a transfer pricing policy that is satisfactory and acceptable for all organizational members involved. Tax managers in multinational enterprises (MNEs), from their side, will explain the difficulties they encounter when fulfilling the transfer pricing tax rules in the different countries in which they operate. This article focuses on the dual role of transfer pricing – managerial versus tax compliance and sheds insights by approaching these issues from a corporate governance perspective. [pic] It is a well known fact that Multi-National Enterprises (MNEs) have found India conducive to set up their operations, largely because of the availability of a skilled work force at reasonable costs. Investments into India result in transactions between the Indian and the parent company as also between the Indian company and other foreign group companies. Such transactions could encompass sale of goods, provision of services, licensing of intangibles, to give a few examples. These transactions give rise to transfer pricing issues. Transfer prices are important for both tax payers and tax authorities because they determine, in large part, the income, expense and taxable profits of the associated (group) enterprises in different tax jurisdictions. Effective April1, 2001, India introduced a comprehensive TP legislation as an anti-avoidance measure. The Indian TP regulations are broadly based on the transfer pricing guidelines issued by the Organization for Economic Co-operation and Development (OECD), but are unique in some respects. The Indian TP regulations mandate that international transactions with related parties shall be determined having regard to the arm's length price, i. e. the price that would be charged by enterprises in an uncontrolled transaction. In India, not only are taxpayers selected for compulsory audits based on quantitative parameters i. . international transactions in excess of INR 50 million in a fiscal year (proposed to be increased to INR 150 million), but further, Indian tax authorities are seen as adopting an increasingly aggressive approach on TP related issues. In several cases, in the recent past, taxpayers faced significant challenges in defending their transfer prices. Taxpayers typically defen d their transfer prices as being at arm's length by conducting a transfer pricing study and comparing their net margins with those earned by comparable uncontrolled enterprises. Therefore, whether a particular transfer price is accepted as being at arm's length or not depends to a large extent on the process of selecting comparable data for the analysis. The lack of quality comparable data in public domain is a challenge faced by the taxpayers while preparing their documentation. This challenge is further compounded by the approach adopted the Transfer Pricing Officers (TPOs) during audits. In addition to using comparable data which was not available at the time of preparing the documentation, TPOs have also resorted to â€Å"cherry-picking† of comparables (especially y eliminating loss making/ low turnover comparables) rather than adopting an objective approach to identifying and screening the comparable companies. This approach creates a bias in favor of profitable companies in the comparable data, resulting in transfer pricing adjustments for the taxpayers. The worst affected were captive service providers, which bear little or no risks as they dea l with parent or group companies as compared to comparable uncontrolled transactions undertaken by other companies which cater to third parties and bear a range of risks including recovery of the price from the third party customers. or captive service providers. It is a fundamental economic principle that entities which However, in a number of instances, TPOs have largely ignored the importance of risk in a transfer pricing analysis and determined high mark ups on costs, to be the arm's length margin do not undertake risks can expect to earn a lower rate of return. Recently, The Delhi Income Tax Appellate Tribunal (ITAT) has revived the hopes of tax payers in India. This decision was given in the case of a captive service provider, Mentor Graphics (Noida) Private Limited, engaged in rendering software services to its US parent. The decision has laid down certain broad principles that could have a significant influence on transfer pricing in India. Steps of Transfer Pricing The scope for Transfer Pricing in such transactions also increases in cases with ‘tie-in’ clauses in licensing agreements or technical/financial collaborations which require the purchase of goods from the licensor or party designated by the licenser. There are three aspects of Transfer Pricing which are:- i) Motivational and Operational Aspect, ii) Regulation of Transfer Pricing, iii) Estimation and control. i) Motivational and Operational Aspect:- Operational and financial manipulations for transfer pricing take the form of false invoicing. This is defined by the OECD Committee on Fiscal Affairs (1976), as- â€Å"A transaction intended to evade tax by putting taxable objects outside the reach of national tax authorities by means of an invoice that does not accord with economic facts† This object is achieved through bo th under and over invoicing (of imports and exports), often by the same company. Policy induced motivation for transfer pricing manipulations may arise because of both tax and non-tax factors. Corporate tax rates and fiscal provisions, exchange rate fluctuations and import duties as also labor laws, policies restricting monopolies International tax avoidance to achieve these and other objectives may occur through general manipulations, as well as through specific items in the balance sheet and the profit and loss account. In BS loans to foreign affiliates may represent the repatriation of foreign profits in an attempt to avoid domestic payment of dividends, as also may excessive balances with affiliates. Write-off of inter company debt may be attempted to reduce balances that may have resulted from non arms length transaction. Omissions in the balance sheet of expected assets or liabilities may indicate transfer or sale of intangible assets like patents, know-how etc to tax affiliates. In P&L A/c, R and D expenditures may be hidden, pooled or distributed to avoid taxes; royalties may be excessive and may go to unlikely recipient affiliates; patents and trademarks may be charged for at monopolistic rates, or involve reciprocal benefits and may be prices even after their expiry. In case of payments, for both royalties and patents and trademarks, to affiliates the charges may not meet with the arm’s length criterion. Payments for home-office administrative support, R and D etc. , may be excessive and may contain hidden profits which are not assessed in the country of receipt. Sales of partly finished goods, third party commissions or discounts to foreign affiliates, unexpected purchases or sales, rentals, office and travel expenses, changes in the pattern of accounts, liquidation and sales of foreign affiliates etc. also provide ample opportunity for transfer pricing and consequently tax avoidance. (ii) Regulation of Transfer Pricing:- In a mixed economy like ours this could mean a misallocation of resources, accompanied by an adverse redistribution of incomes away from national entities and the related BOP effects. Before dealing with transfer pricing before it can occur and after it has occurred, policy regulation is therefore also required, to deal with its macro economic consequences. The adverse impact on host government foreign exchange; revenue losses and the consequent implications for internal resources mobilization; distortion in the functioning of specific policy instruments resulting in the non-achievement of plan targets; all call for an active role of the state. Similarly, at the micro level the proliferation of market concentration and oligopolistic practices require state intervention. (iii) Estimation and Control:- 1). Any proper appraisal of the scope of transfer pricing manipulations on the part of transnational corporations, and of their actual practice must be assessed within the framework of the specific set of government measures and structural factors endemic to TNCs which tend to be the motivational forces behind such practices. 2). Abandon the free market model and allow for a changed role of the state, from one of trying to restore some traditional version of market relations to that of an active intervener in the struggle over international distribution of surplus. Keeping in mind these approaches, we would like to focus on the problem of estimation the extent of pricing manipulations by TNCs, in various sectors and industries in developing countries, in the context of relevant government policies and regulations. Exemption for Bankers Bankers have sought an exemption from the provisions of transfer pricing regulations. When banks extend loans and guarantees by way of investment in equity, this may lead to the specified shareholding limits being exceeded. Though the banks may not have any control over the company, such transactions are subjected to transfer pricing rules of the Income Tax Act. In their meeting with the finance minister earlier this month, public sector banks had said banks should be excluded from the purview of the transfer pricing provisions under the income tax law. Current regulations also cover loans advanced for not less than 51% of the book value of the total assets of the borrower and guarantees granted for more than 10% of the total borrowings of the guarantor. But experts feel that banks do not usually have so much exposure to a single borrower. Banks provide financial assistance to various corporate and non-corporate clients by way of investment in equity or preference shares, subscription to debentures, loans and guarantees. Under section 40A(2) of the Income Tax Act, any expenditure incurred between related parties treated as unreasonable by the assessing officer is not allowed as a deduction. This section empowers an assessing officer to disallow deduction of any expenditure incurred between related parties and considered by the officer as excessive or unreasonable having regard to the fair market value of the goods, services or facilities. Similar restrictions are applicable to banks according to the transfer pricing provisions under sections 92 A to 92F. The scope of related person under section 40A(2) for a banking company includes a person in whom it has a substantial interest in the business, where ownership of shares is not less than 20% of the voting power. However, according to Reserve Bank of India regulations, voting powers are limited to 10%, irrespective of the ownership of shares. The transfer pricing provisions (sections 92 to 92F) only apply to transactions between two non-residents or between a resident and a non-resident and not to transactions between Indian banks and Indian counterparties. â€Å"While the transfer pricing provisions can be applied to transactions between the foreign subsidiaries of Indian banks and Indian counterparties, only under very rare exceptions do such foreign subsidiary banks have an exposure to unrelated borrowers to bring their transactions within the transfer pricing rules. â€Å"Also, it is unlikely that transactions between Indian branches of foreign banks and Indian counterparties would result in a loan greater than 51% of the book value of assets of the borrower for the transfer pricing rules being made applicable to genuine third party transactions. The objective of transfer pricing is that the correct amount of profits should be retained within the country and thus the transfer pricing provisions should be made inappl icable to transactions between Indian branches of foreign banks and the group’s related Indian companies,† Mr Wadhwani added. While lending, banks may grant loans at fluctuating rates compared with market rates after factoring in risk factors, creditability and type of industry. Given that the pricing adopted is within the framework of norms outlined by banks that are regulated by RBI, the Indian Banks Association is of the view that banks should be removed from the purview of such sections TYPICAL CASH FLOW The question arises that how the transfer price can be used as a mechanism to evade tax, especially between countries that have a treaty against double taxation. To explain this let’s take an example. Suppose there is an MNC shoe corporation with a subsidiary in India. The Indian subsidiary manufactures shoes at a cost price of Rs 50 per unit and supplies it to the MNC. The MNC sells the same shoes in its own country at Rs 200. To be fair, the transfer price, which the Indian subsidiary should get, is cost plus a reasonable rate of return (i. e. Rs 50 plus). This is where the MNC company calls the shots. In India, the corporate tax on profits is at 35%. Suppose for the MNC country the rate of tax is 45%. Case 1. The MNC decides that Rs 100 is the correct transfer price. Then the scenario looks like this: Transfer Price at Rs 100 |Indian subsidiary |MNC |Grand Total | |Cost price |50 |100 |   | |Selling price |100 |200 |   | |Profit |50 |100 |150 | |Tax |17. 5 |45 |62. 5 | |Net Profit |32. 5 |55 |87. 5 | The transfer price becomes the cost price for the MNC and thus it earns a profit of Rs 100 per unit. Post tax, its profit is whittled down to Rs 55. Overall, the total profit after tax earned by the MNC (including the subsidiary’s profit) is Rs 87. per unit. Case 2. The MNC decides that Rs 150 is the correct transfer price. Then the scenario looks like this: Transfer Price at Rs 150 |Indian subsidiary |MNC |Grand Total | |Cost price |50 |150 |   | |Selling price |150 |200 |   | |Profit |100 |50 |150 | |Tax |35 |22. 5 |57. 5 | |Net Profit |65 |27. 5 |92. 5 | The MNC’s profits post tax in its own country comes down to Rs 27. 5. But overall the profit surges to Rs 92. 5 per unit. Case 3. The MNC decides that Rs 200 is the correct transfer price. In such a case, the MNC earns zero profits in its own country, but its subsidiary pays a 35% tax on its profit of Rs 150 and thus overall net profit surges to Rs 97. 5. Transfer Price at Rs 200 |Indian subsidiary |MNC |Grand Total | |Cost price |50 |200 |   | |Selling price |200 |200 |   | |Profit |150 |0 |150 | |Tax |52. 5 |0 |52. 5 | |Net Profit |97. 5 |0 |97. 5 | Case 4. The MNC decides that Rs 300 is the correct transfer price. In this case, the MNC earns a loss of Rs 100 per unit of shoe sold in the home country. Meanwhile, its subsidiary earns Rs 162. 5 as profit, after paying Rs 87. 5 as tax. But the clever MNC gets a tax write off at home worth Rs 45 m. Transfer Price at Rs 300 |Indian subsidiary |MNC |Grand Total | |Cost price |50 |300 |   | |Selling price |300 |200 |   | |Profit |250 |-100 |150 | |Tax |87. 5 |-45 |42. | |Net Profit |162. 5 |0 |192. 5 | Please remember, these are just a few hypothetical simple situations. In reality, these dealings are much more complex with conglomerates having more than 50 subsidiaries in just as many countries. Transfer pricing became a subject of much debate in the western countries as government’s felt that corporates are down paying their fair share of tax. As a result, these countries spearheaded awareness regarding transfer pricing. Case Study High Court Rules Against Coca-Cola in Tra nsfer Pricing Case M Padmakshan Economic Times January 6, 2009 MUMBAI: The Punjab & Haryana High Court has ruled against Coca-Cola India's contention that the proof of profit transfer outside India is a precondition for applying transfer pricing rules. Coca-Cola had approached the high court after it was served a notice on transfer pricing. The soft drink company had an agreement to offer advisory services to Britco at the rate of cost plus 5%. Coca-Cola's main contention was that transfer pricing rules cannot be applied in the absence of prima facie evidence of profit transfer outside India. The high court said that India's transfer pricing rules can be applied to any cross-border transaction between associated enterprises, irrespective of profit transfer outside India. The court said the only requirement is income generation in a cross-border transaction and income has been computed at arms length. Coca-Cola told the court that transfer pricing rules were meant to check profit erosion outside India and therefore could not be applied in cases where there is no prima facie evidence of profit transfer outside the country. The high court did not accept this view. It held that existence of a cross-border transaction and computation of the resultant income at arm's length price are sufficient grounds for applying transfer pricing rules. According to Coca-Cola, the transfer pricing provisions have been incorporated in the Income-tax Act by the Finance Act 2001 and the applicability of these provisions has been limited to situations involving profit diversion outside India. There is no material evidence to show that profits have been diverted outside India, the company said. The court said that it is the prerogative of the income-tax department to issue such a notice and expressed its inability to intervene in the matter. Coca-Cola was assessed under I-T Act in 2004 for the year 1998-99. The dispute arose after the income-tax department concluded that the income had escaped assessment under the Income-Tax Act. FAIR USE NOTICE: – This document contains copyrighted material whose use has not been specifically authorized by the copyright owner. India Resource Center is making this article available in our efforts to advance the understanding of corporate accountability, human rights, labor rights, social and environmental justice issues. We believe that this constitutes a ‘fair use' of the copyrighted material as provided for in section 107 of the U. S. Copyright Law. If you wish to use this copyrighted material for purposes of your own that go beyond ‘fair use,' you must obtain permission from the copyright owner. Arm’s Length Method Arm’s length, as the term indicates, means keeping a neutral balance between inter-corporate arms. The idea is that companies should treat each subsidiary as a separate entity and deal with them on purely commercial terms, as they would have if they transacted with any other market player. Arm’s length methodologies are of two types:- a) Transactional Methods b) Profit Methods Transactional Methods – Where focus is on the product or the technology to ascertain the correct transfer price. Transaction methods can be further divided into three broad sub-groups. ) Comparable Uncontrolled Price Method 2) Resale Price Method 3) Cost Plus Method (1) Comparable Uncontrolled Price (CUP) Method: The price charged or paid in a comparable uncontrolled transaction or a number of such transactions shall be identified. Such price shall be adjusted to account for differences, if any, between the related party transaction and the comparable uncontrolled transactions or between th e enterprises entering into such transactions, which could materially affect the price in the open market. The adjusted price shall be taken as arm’s length price. The uncontrolled transaction means a transaction between independent enterprises other than related parties and shall cover goods or services of a similar type, quality and quantity as those between the related parties and relate to transactions taking place at a similar time and stage in the production/distribution chain with similar terms and conditions applying. (2) Resale Price Method: The price at which the goods purchased or services obtained from a related party is resold or is provided to an unrelated entity shall be identified. Such resale price shall be reduced by the amount of a normal gross profit margin accruing to the enterprise or to an unrelated enterprise from the purchase and resale of the same or similar goods or services in a comparable uncontrolled transaction or a number of such transactions. The price so arrived at shall be further reduced by the expenses incurred by the enterprise in connection with the purchase of goods or services. Such price shall be further adjusted to take into account the functional and other differences including differences in accounting practices, if any, between the related party transaction and the comparable uncontrolled transactions or between the enterprises entering into such transactions, which could materially affect the amount of gross profit margin in the open market. The adjusted price shall be taken as arm’s length price in respect of goods purchased or services obtained from the related party. The resale price method would normally be adopted where the seller adds relatively little or no value to the product or where there is little or no value addition by the reseller prior to the resale of the finished products or other goods acquired from related parties. This method is often used when goods are transferred between related parties before sale to an independent party. (3) Cost Plus Method: The total cost of production incurred by the enterprise in respect of goods transferred or services provided to a related party shall be determined. The amount of a normal gross profit mark-up to such costs arising from the transfer of same or similar goods or services by the enterprise or by an unrelated enterprise in a comparable uncontrolled transaction or a number of such transactions shall be determined. The amount of a normal gross profit mark-up shall be adjusted to take into account the functional and other differences, if any, between the related party transaction and the comparable uncontrolled transactions or between the enterprises entering into such transactions, which could materially affect such profit mark-up in the open market. The total cost of production referred to above increase by the adjusted profit mark-up shall be taken as arm’s length price. It is also important here to ensure that the cost base to which mark-up is applied is comparable to the cost base of the third party transaction which serves as comparable. For example, it may be necessary to make an adjustment to cost where one person leases its business assets while other owns its business assets. The cost plus method would normally be adopted if CUP method or resale price method cannot be applied to a specific transaction or where goods are sold between associates at such stage where uncontrolled price is not available or where there are long term buy and supply arrangements or in the case of provision of services or contract manufacturing. Profit method- It has been further sub-divided into three sub-groups i) Profit Split Method ii) Transactional Net Margin Method iii) Authentication of Documents Provided by the Company (1) Profit Split Method: The combined net profit of the related parties arising from a transaction in which they are engaged shall be determined. This combined net profit shall be partially allocated to each enterprise so as to provide it with a basic return appropriate for the type of transaction in which it is engaged with reference to market returns achieved for similar type transactions by independent enterprises. The residual net profit, thereafter, shall be split amongst the related parties in proportion to their relative contribution to the combined net profit. This relative contribution of the related parties shall be evaluated on the basis of the function performed, assets employed or to be employed and risks assumed by each enterprise and on the basis of reliable market data which indicates how such contribution would be evaluated by unrelated enterprises performing comparable functions in similar circumstances. The combined net profit will then be split amongst the enterprises in proportion to their relative contributions. The profit so apportioned shall be taken into account to arrive at an arm’s length price This method would normally be adopted in those transactions where integrated services are provided by more than one enterprise or in the case multiple inter-related transactions which cannot be separately evaluated. 1) Transactional Net Margin Method : The net profit margin realized by the enterprise from a related party transaction shall be computed in relation to costs incurred or sales affected or assets employed or to be employed by the enterprise or having regard to any other relevant base. The net profit margin realized by the enterprise or by an unrelated enterprise from a comparable uncontrolled transaction or a number of such transactions, shall also be computed having regard to the same base. This net profit margin shall be adjusted to take into account the differences, if any, between the related party transaction and the comparable uncontrolled transactions or between the enterprises entering into such transactions, which could materially affect such net profit margin in the open market. The cost of production referred to above increase by the adjusted profit mark-up shall be taken as arm’s length price. The adjusted net profit margin shall be taken as arm’s length price. This method would normally be adopted in the case of transfer of semi finished goods; distribution of finished products where resale price method cannot be adequately applied; and transaction involving provision of services. (3) Authentication of the documents provided by the company The information/documents provided by the company to the auditor for certification as provided in clause 7 hereof shall be signed on behalf of the Board by the Company Secretary and at least one Director of the company. In the absence of Company Secretary in the company, the same shall be signed by at least two Directors of the company on behalf of the Board. [pic] The most appropriate method referred to in sub-section (1) shall be applied, for determination of arms length price, in the manner as may be prescribed: Provided that where more than one price is determined by the most appropriate method, the arms length price shall be taken to be the arithmetical mean of such prices, or, at the option of the assessee, a price which may vary from the arithmetical mean by an amount not exceeding five per cent of such arithmetical mean. ] Where during the course of any proceeding for the assessment of income, the Assessing Officer is, on the basis of material or information or document in hi s possession, of the opinion that:- (a)The price charged or paid in an international transaction has not been determined in accordance with sub-sections (1) and (2); or b)any information and document relating to an international transaction have not been kept and maintained by the assessee in accordance with the provisions contained in sub-section (1) of section 92D and the rules made in this behalf; or (c)The information or data used in computation of the arms length price is not reliable or correct; or (d)the assessee has failed to furnish, within the specified time, any information or document which he was required to furnish by a notice issued under sub-section (3) of section 92D, The Assessing Officer may proceed to determine the arms length price in relation to the said international transaction in accordance with sub-sections (1) and (2), on the basis of such material or information or document available with him: Provided that an opportunity shall be given by the Assessing Officer by serving a notice calling upon the assessee to show cause, on a date and time to be specified in the notice, why the arms length price should not be so determined on the basis of material or information or document in the possession of the Assessing Officer. Where an arms length price is determined by the Assessing Officer under sub-section (3), the Assessing Officer may compute the total income of the assessee having regard to the arms length price so determined: Provided that no deduction under section 10A 82[or section 10AA] or section 10B or under Chapter VI-A shall be allowed in respect of the amount of income by which the total income of the assessee is enhanced after computation of income under this sub-section : Provided further that where the total income of an associated enterprise is computed under this sub-section on determination of the arms length price paid to another associated enterprise from which tax has been deducted 83[or was deductible] under the provisions of Chapter XVIIB, the income of the other associated enterprise shall not be recomputed by reason of such determination of arms length price in the case of the first mentioned enterprise. While going through each of these methods, it becomes clear that all these methods are not definitive methods for ascertaining transfer prices. Being a complex subject, more fine-tuning is needed to finally get a definitive benchmark method for calculating the transfer price. As business between countries is likely to only increase in future, transfer-pricing issues would be subject of even more scrutiny not only by government and legal bodies, but also the companies’ respective shareholders. But there is a lot of ground still to be done in this area. Speaking on the sidelines of a budget analysis session organized by Confederation of Indian Industry, Rohan K Phatarphekar, executive director nd national head, global transfer pricing services KPMG India Private Limited said, â€Å"The Budget was not bad, there was too much of expectations from the market. What the Budget lacked was clarity, the government failed to lay down a concrete roadmap to bridge the fiscal deficit. † But significant changes were announced in the tax structure like removal of FBT, removal of 10 per cent surcharge on the higher bracket of i ncome tax, commitment to introducing GST. [pic] Difficulties in applying Arm’s Length Principle . Multinational Enterprises groups are dealing in the integrated production of highly specialized goods, in unique intangibles, and in the provision of specialized services. 2. Associated Enterprises may engage in transactions that independent would not undertake, example sale or license of intangibles. 3. Arm’s Length Price may result in an administrative burden for both the tax administrations of evaluating significant numbers and types of cross-border transactions. 4. Far placed geographical locations and confidentiality etc. may cause difficulty in obtaining comparable data. Transfer Pricing in IT Department Commercial transactions between the different parts of the multinational groups may not be subject to the same market forces shaping relations between the two independent firms. One party transfers to another goods or services, for a price. That price is known as transfer price. This may be arbitrary and dictated, with no relation to cost and added value, diverge from the market forces. Transfer price is, thus, a price which represents the value of good; or services between independently operating units of an organization. But, the expression transfer pricing generally refers to prices of transactions between associated enterprises which may take place under conditions differing from those taking place between independent enterprises. It refers to the value attached to transfers of goods, services and technology between related entities. It also refers to the value attached to transfers between unrelated parties which are controlled by a common entity. Example of using Transfer Pricing Suppose a company A purchases goods for 100 rupees and sells it to its associated company B in another country for 200 rupees, who in turn sells in the open market for 400 rupees. Had A sold it direct, it would have made a profit of 300 rupees. But by routing it through B, it restricted it to 100 rupees, permitting B to appropriate the balance. The transaction between A and B is arranged and not governed by market forces. The profit of 200 rupees is, thereby, shifted to the country of B. The goods is transferred on a price (transfer price) which is arbitrary or dictated (200 hundred rupees), but not on the market price (400 rupees). Thus, the effect of transfer pricing is that the parent company or a specific subsidiary tends to produce insufficient taxable income or excessive loss on a transaction. For instance, profits accruing to the parent can be increased by setting high transfer prices to siphon profits from subsidiaries domiciled in high tax countries, and low transfer prices to move profits to subsidiaries located in low tax jurisdiction. As an example of this a group which manufactures products in high tax countries may decide to sell them at a low profit to its affiliate sales company based in a tax haven country. That company would in turn sell the product at an arm's length price and the resulting (inflated) profit would be subject to little or no tax in that country. The result is revenue loss and also a drain on foreign exchange reserves Reference to Transfer Pricing Officer. 92CA. (1) Where any person, being the assessee, has entered into an international transaction in any previous year, and the Assessing Officer onsiders it necessary or expedient so to do, he may, with the previous approval of the Commissioner, refer the computation of the arm’s length price in relation to the said international transaction under section 92C to the Transfer Pricing Officer. (2) Where a reference is made under sub-section (1), the Transfer Pricing Officer shall serve a notice on the assessee requiring him to produce or cause to be produced on a date to be specified therein, any evidence on which the assessee may rely in support of the computation made by him of the arm’s length price in relation to the international transaction referred to in sub-section (1). 3) On the date specified in the notice under sub-section (2), or as soon thereafter as may be, after hearing such evidence as the assessee may produce, including any information or documents referred to in sub-section (3) of section 92D and after considering such evidence as the Transfer Pricing Officer may require on any specified points and after taking into account all relevant materials which he has gathered, the Transfer Pricing Officer shall, by order in writing, determine the arm’s length price in relation to the international transaction in accordance with sub-section (3) of section 92C and send a copy of his order to the Assessing Officer and to the assessee. 4a[(3A) Where a reference was made under sub-section (1) befo re the 1st day of June, 2007 but the order under sub-section (3) has not been made by the Transfer Pricing Officer before the said date, or a reference under sub-section (1) is made on or after the 1st day of June, 2007, an order under sub-section (3) may be made at any time before sixty days prior to the date on which the period of limitation referred to in section 153, or as the case may be, in section 153B for making the order of assessment or reassessment or re computation or fresh assessment, as the case may be, expires. ] 84b[(4) On receipt of the order under sub-section (3), the Assessing Officer hall proceed to compute the total income of the assessee under sub-section (4) of section 92C in conformity with the arm’s length price as so determined by the Transfer Pricing Officer. ] (5) With a view to rectifying any mistake apparent from the record, the Transfer Pricing Officer may amend any order passed by him under sub-section (3), and the provisions of section 154 sha ll, so far as may be, apply accordingly. (6) Where any amendment is made by the Transfer Pricing Officer under sub-section (5), he shall send a copy of his order to the Assessing Officer who shall thereafter proceed to amend the order of assessment in conformity with such order of the Transfer Pricing Officer. 7) The Transfer Pricing Officer may, for the purposes of determining the arm’s length price under this section, exercise all or any of the powers specified in clauses (a) to (d) of sub-section (1) of section 131 or sub-section (6) of section 133. Undesirable Corporate Practices Related to Transfer Pricing Some of the related party transactions, which are usually resorted to for diversion of funds are detailed below. (a)  Ã‚  Ã‚   Purchase of goods or services from a related party at little or no cost or at inflated prices to the entity. (b)  Ã‚   Payments for services never rendered or at inflated prices. (c)  Ã‚  Ã‚   Sales at below market rates to an unnecessary â€Å"middle man† related party, who in turn sells to the ultimate customer at a higher price with the related party (and ultimately its principals) retaining the difference. (d)  Ã‚   Purchases of assets at prices in excess of fair market value. e)  Ã‚  Ã‚   Use of trade names or patent rights at exorbitant rates even after their expiry or at a price much higher than the price, which can not be described as reasonable. (f)  Ã‚  Ã‚  Ã‚   Borrowing or lending on an interest-free basis or at a rate of interest significantly above or below market rates prevailing at the time of the transaction. (g)  Ã‚  Ã‚   Exchanging property for similar property in a non monetary transaction. (h)  Ã‚  Ã‚   Selling real estate at a price that differs significantly from its appraised value. (i)  Ã‚  Ã‚  Ã‚  Ã‚   Accruing interest at above market rates on loans. Associated Enterprise. 92A. (1) For the purposes of this section and sections 92, 92B, 92C, 92D, 92E and 92F, associated e nterprise, in relation to another enterprise, means an enterprise a)Which participates, directly or indirectly, or through one or more intermediaries, in the management or control or capital of the other enterprise; or (b)In respect of which one or more persons who participate, directly or indirectly, or through one or more intermediaries, in its management or control or capital, are the same persons who participate, directly or indirectly, or through one or more intermediaries, in the management or control or capital of the other enterprise. (2) 77[For the purposes of sub-section (1), two enterprises shall be deemed to be associated enterprises if, at any time during the previous year,] (a)one enterprise holds, directly or indirectly, shares carrying not less than twenty-six per cent of the voting power in the other enterprise; or b)any person or enterprise holds, directly or indirectly, shares carrying not less than twenty-six per cent of the voting power in each of such enterpris es; or (c)a loan advanced by one enterprise to the other enterprise constitutes not less than fifty-one per cent of the book value of the total assets of the other enterprise; or (d)One enterprise guarantees not less than ten per cent of the total borrowings of the other enterprise; or (e)more than half of the board of directors or members of the governing board, or one or more executive directors or executive members of the governing board of one enterprise, are appointed by the other enterprise; or f)more than half of the directors or members of the governing board, or one or more of the executive directors or members of the governing board, of each of the two enterprises are appointed by the same person or persons; or (g)the manufacture or processing of goods or articles or business carried out by one enterprise is wholly dependent on the use of know-how, patents, copyrights, trade-marks, licenses, franchises or any other business or commercial rights of similar nature, or any da ta, documentation, drawing or specification relating to any patent, invention, model, design, secret formula or process, of which the other enterprise is the owner or in respect of which the other enterprise has exclusive rights; or h)ninety per cent or more of the raw materials and consumables  required for the manufacture or processing of goods or articles carried out by one enterprise, are supplied by the other enterprise, or by persons specified by the other enterprise, and the prices and other conditions relating to the supply are influenced by such other enterprise; or (i)the goods or articles manufactured or processed by one enterprise, are sold to the other enterprise or to persons specified by the other enterprise, and the prices and other conditions relating thereto are influenced by such other enterprise; or (j)Where one enterprise is controlled by an individual, the other enterprise is also controlled by such individual or his relative or jointly by such individual and relative of such individual; or k)Where one enterprise is controlled by a Hindu undivided family, the other enterprise is controlled by a member of such Hindu undivided family or by a relative of a member of such Hindu undivided family or jointly by such member and his relative; or Chapter 2 Objectives of the Study Objectives of the Study:- Primary Objectives: 1) To study the acceptability of different methods of Transfer Pricing in the companies. 2) To find out the ways of applying Arm’s Length Method and the results of it. 3) To study the different terms like Associated Enterprises, Transfer pricing officer, International Transaction & Subsidiary company etc. Secondary Objectives 1) To identify various other ways of managing the profit of the company. 2) To analyse different ways of applying extra cash flow. ) To find different ways of Transfer Pricing which are applicable under Income Tax Act 1961. Chapter 3 Company Profile COMPANY PROFILE PARAMOUNT Established in 1993, P aramount Surgimed Ltd. manufactures wide range of Surgical Blades, Scalpels which cover General Surgery and other Surgical Area viz: Gastroentrology, Urology, Orthopedic & General Surgery etc. Paramount Surgimed Ltd. is exporting their products in more than 50 countries. Paramount Surgimed Ltd. is first Company who has been approved by ISI, ISO 9001 & FDA registered company and their products are CE marked. A guiding sense of concern for mankind and a mission to realize richer human life led to the birth of PARAMOUNT SURGIMED LTD. Paramount has grown with a reputation of specializing in manufacturing of a wide range of single use medical and surgical devices such as Surgical Blades, Disposable Scalpels, Stitch Cutters and Skin Graft Blades. Paramount has its corporate head office in New Delhi, the capital of India & operates its major production activities from Bhiwadi in Rajasthan. This has a floor space of 30000 sq. ft. on 10000 sq. meter. plot and a mere 60 km from the Capital City. The facilities comprise of latest state – of – the – art – manufacturing unit comparable to international standards. Paramount is committed to exceed it’s customer's expectations. All aspects of manufacturing and packaging is done in a clean & controlled environment. We adhere to the policy of strict quality control without mercy by making use of in – house test laboratory, for competitive quality assurance at all times. Blades are sterilized through Gamma Radiation in New Delhi. We are an ISO 9000: 2000 company and the products are CE marked. Our products are also registered with various health ministries around the world. Vision Statement Today India is at the down of the millennium’s exciting future with the liberalization and the opening up of its economy. The world is taking a look at India, her products, and her enterprises. With a vision of being a global leader in Medical Disposables, Paramount Surgimed Ltd. dedicates itself to the crucial sector. Mission Statement We at  Paramount Surgicals, Inc are committed to  design, manufacture and distribute finest spinal implant and instruments. Since its beginning, Paramount Surgical, Inc has stood for one capability above all others – the ability to Innovate. Innovate  is a sense of possibility that allows for freedom beyond mere innovation. We strive without reserve for the greatest possible reliability and quality of our products and to be recognized in the market for our dedication, honesty and services. Paramount Surgimed Limited has created this privacy statement in order to demonstrate our firm commitment to privacy. The following discloses the information gathering and dissemination practices for our Corporate Web site: www. paramountblades. com. . R & D Technology Mission We fully understand the grave implications of technology and are constantly on the move to keeping abreast with rapid technological development towards the quest for excellence in the field of Medical & Surgical disposables. The R & D department not only helps in developing new products and their manufacturing technologies but also in improving existing ones. Quality Commitment Paramount has kept alive quality as a legacy in which quality is not an end but a vehicle for seeking excellence & perfection at all stages. We are committed to exceed our customer's expectations. All aspects of manufacturing and packaging is done in a clean & controlled environment. We adhere to the policy of strict quality control without mercy by making use of in – house test laboratory, for competitive quality assurance at all times. Blades are sterilized through Gamma Radiation in New Delhi. We are an ISO 9000 : 2000 company and the products are CE marked. Our products are also registered with various health ministries around the world Step in to the Future Encouraged with the continued impressive performance, Paramount has decided to expand & diversify in to the other related areas, targeting the year leading into 21st century. Paramount will build additional new manufacturing facilities equipped with latest technologies in the field of healthier business. The responsibility and obligation to the customer to supply the best products in every way is the power of its efforts. Like the tip of an iceberg, only a small part of its work is visible. The significant strength however is the use of most progressive and modern technologies, and the untiring efforts of its employees, who continue to strive for more efficient and better solutions. Response by placing repeat orders for years together, Paramount has a sustained and consistent growth. OSIM Delhi based Paramount Surgimed Ltd. has signed a Master Franchisee Agreement with OSIM International Ltd. , over $ 300 million company and Singapore's largest manufacturer of lifestyle products to import and trade OSIM products in India and Nepal through OSIM India, a division of Paramount Surgimed Ltd. Established in 1980, OSIM is the No. brand in lifestyle products in Singapore, Hong Kong, Taiwan, and Malaysia, UK & USA, Australia, Canada and over 22 franchisee all over the world. OSIM produces superior designs focusing and following ergonomic guidelines along with quality features. OSIM India has opened 23 outlets in the country in just one year. These include outlets in Delhi, Gurgaon, Ludhiana, Kolkata Bangalore, Chennai, Mumbai, Hyderabad, Pune and Indore. By the end of this year it plans to expand and set up a total of 25 more outlets. Quality As we offer lifestyle products related to health, quality is the most important factor that, we take special care of. Our products are completely flawless and stand at par even with the international standards. All our products are checked and tested under strict supervision of experts and doctors, so that they do not cause any adverse health effects. Specially equipped with quality experts who individually examine the products themselves so that our clients can use it in a comfortable way. Fully guaranteed our products have been manufactured with complete care, perfection and precision by world class procedures. Believing in the motto â€Å"quality begins with us†, we have earned enormous accolades. Operations 1. Human Resource:- The Company is having a manpower of around 530 employees all over India. To maintain the proper management on this vast manpower, the company uses the Master Software, â€Å"Portal Data Management†. The turnover ratio of manpower is around 110 employees in a year. Process of Recruitment- To do the recruitment firstly the Manpower assessment is done, then approval is taken from the Heads, HOD’s and then permission is taken from COO’s Basically the company tries to fill the gap internally, by posting the existing employee at the new post, personal sources of employees, their relatives and friends and then if necessary it uses the job portals available on-line and scrutinize the resumes available there. Then the company conduct interview (no G. D. is done), firstly with HR personals then with concern HODs. This process ends for the post of a Front line officer. If a higher person is to be recruited then the interview with COO is also conducted. Then the final result is taken regarding that candidate. Documents to be carried on the date of joining and everything else except the salary (salary is included because many person negotiate other companies on the basis of this LOC) Probationary Period for the new employee remains for 6 months and after that, if he/she (if found suitable), is given permanent employee certificate. Training and Development- Generally the training is provided in the concerning departments only by the employees already working over there. Basically two types of training is provided. i. Product/Technical Training- In this, the training is provided regarding the products of the company and also the work which the new employee is to be done. This includes the hard core training. ii. Soft skills/Non-technical Training- In this training, the soft skills are taught to the candidate, like the behavior of the employees, working conditions, organizational culture etc. Time to time the employees development programs are also conducted to motivate the employees i. e. to understand their personal problem, solving it out, developing their career path, etc 2. I. T. The company is having one single IT department to control all the data base management and all the networking facilities. This department is in head office. The company uses its own made OSIM Software to keep the data and all of its branches are using the same software, which is downloaded by the head office personals with the SQL information. The company is also engaged in on line merchandizing, it makes online sales also with the help of its website. It uses OSIM India as the selling website which is fully organized by the Head Office only. 3. Accounts The Company’s Accounts Department is near to Head Office. The Accounts Department is having a workflow of 25 members who are handling the accounts of the different branches of the Company. The Company is using Tally 9 Software along with MS Office to maintain the records of the customers 4. Marketing:- The Company is having a highly powerful Marketing activity which is the biggest strength of the company. The products of Paramount are traded in both domestic and international markets. Our medical products are being exported to more than 40 Countries across the world like USA, Asia, and South Africa etc. Moreover, OSIM is declared as Asia No. 1 healthy lifestyle brand in consumers’ minds It basically having two types of Sale i. e. a) Corporate- The Company is having almost 35% of its total sales in the Corporates. Its Corporate clients includes ONGC, Japee Hotels, Indian Oil, Hyath Group of Hotels, Apollo Tyres, Apollo Hospitals, Heritage Hospitals, Fortis Hotels etc. The Company is having a big ratio of its sales in Indian Army and other PSU’s b) Retails- The Company’s Retailing is very strong. Almost 65-70% of its sales is based on Retailing. Its Retailing is very wide, which is divided in three modes i. Showrooms- The Company has opened its own Showrooms in different parts of the country, including Chandigarh, Delhi, Ludhiana, Ahemdabad, Kerla, Hyderabad, and many other places. The Showrooms are exclusively defined, and highly modernized, with all the facilities for the visitors. ii Shop in Shops- At many places the Company is having its shops in different shops. This is a very new concept which provide the firm to save money and also having more attention form the visitors along with standing with other different renowned Brands. iii Road Shows- The company has a mode of selling through Road Shows. Road Shows are very popular in Metro Cities and a large amount of sales of the Company is dependent on that. The Company is having its all time Road Show in Delhi, Bangalore, Kolkata, Chennai etc. Products iMedic Chair Revolutionary chair designed for precise massage The new OSIM iMedic Chair is the first of its kind to cater to the specific needs of every individual by detecting the precise location of acupressure points along the back. With more than 300 acupressure points in the body, every person’s body shape is as different as the shape of our face. Determining the exact body shape of the use allows a more sensitive massage to be applied effectively to just the right spot, helping to relieve fatigue and neuralgia, promote blood circulation, ease muscle strain and stiffness, leaving you feeling relaxed all over. Sit back, close your eyes and sink into the luxuriousness of the OSIM iMedic Chair as you relinquish your body to the ultimate massage experience. Detecting Acupressure Points: While seated deeply into the OSIM iMedic Chair with your head resting comfortably on the headrest pad, select any of the 8 comprehensive massage programmes. Before commencement of any programme, the massage rollers automatically glide along the length of your back to detect the acupressure points via 2 infrared sensors. Once detected, you can look forward to a massage experience unlike any other. Shoulder Position Adjustment: You can further personalize the massage programmed by adjusting the position of the rollers at your shoulder area, so you can pinpoint the massage precisely where you want it. Well-being Programmes: These 3 relaxing programmed are designed to enhance your health by adapting massage treatment to your daily routine. Morning Programme: For those who feel an ongoing tiredness and a lack of energy during the day, giving you the extra perk you need Night-time Programme: Use at the end of the day to fully relax your body and prepare you for a good rest. Useful if you suffer from insomnia. Seat Programme: Massages the hip area using a combination of vibration action and seat message. Useful for relief of constipation discomfort. Luxurious Comfort Versatile Design The OSIM iMedic Chair has been designed with features to raise the level of comfort to unparalleled heights. Fully Automatic Reclining System: Recline the backrest and/or the footrest independently at the siple touch of the Remote Controller to find the position that suits you best. Adjustable Angle: The backrest can be reclined up to 170 degree for greater comfort. Extendable Footrest: The footrest can be easily extended to cater to the height of the user. Auto-Timer: Whichever programme you chose, it will automatically run for a maximum of 15 minutes, allowing you to relax your mind while the OSIM iMedic Chair relaxes your body. However, you can turn the programme off or switch to a different programme at any point and the timer will reset automatically. Total Remote Control: A comprehensive Remote Controller with two LCD display screens controls all programmes and functions for an uninterrupted massage session. Anti-bacterial Upholstery Covers: The upholstery covers are specially coated with an anti-bacterial treatment, keeping bacteria like Staphylococcus, Yellow Coliform Bacilli and MRSA at bay. They are completely removable for easy cleaning. Available in white, black, latte and olive. Foldable Backrest and Castors: For easy storage and transportation. Paramount Surgimed Ltd, New Delhi has been chosen as Master Franchise to represent OSIM in India. OSIM India A Division of Paramount Surgimed Ltd shall be promoting a wide range of OSIM products through our exclusive showroom to start with in New Delhi and followed by in other cities. OSIM International Ltd, Singapore came in to existence in the year 1980 with the aim to provide a healthy lifestyle to the mankind. From a humble start to $287. 4 million company, today OSIM is promoting its products through is Master Franchise in over 20 countries. OSIM INDIA is coming up with a top of the line massage chair in India Millennium Chair OS – 747iv: The Master Of Relaxation. Equipped with a specially designed roller system, which moves in a wavelike motion along your spine to effectively massage muscoes relieve aches and stiffness. Bliss Chair NR-90: Complete Relaxation from Top to toe. Full body massage with a unique reversible footrest, which gives you a choice of resting your legs, or treating your feet and calves to a stimulating massage. Apart from the above products we have a Reflexologist, i Twin, Foot Reivitalizer 2, Tappie (Handy Massager), Warm Air Turbo, eHuman-logic BPM, Pro Therapist, Massuer Chair, Hair Brush, Ear Scan, Health Sole, Eye Care Massager, Large Gel Pad, Samll Gel Pad, VF scan, e-Body fat Scale, Fever Band, Handy Neb, Ultrasonic Neb, Instant Heat Pad (small), Slim Belt (Aerobics), Slim Belt (Body Shaping), Slim Belt (back support), Slim Belt (Extra Support), Spare Wire, Upholstery for OS777, Music CD for OS777, I. Sense Upholstery for OS757 to add to the big range of products. Chapter 4 Research Methodology RESEARCH METHODOLOGY Methodology is the bone of a project. It has also an important place as regards to cash management system project. It helps us in Collection and analysis of data in preparing the project. My Research is purely a Descriptive Research, which includes understanding and analyzing Transfer Pricing and its different Method. My sources of collection of data must be very much reli able, so secondary data collection method is used for the purpose of the project for the Price Management System. I have gone very deeply in preparing the project & I devoted my full attention to get the accurate & real data collection. For this purpose I became in close contact with sources of data collection by personally & through Internet. The Methodology contains the following things:- †¢ Methods of Data Collection :- For the project report, methods of data collection has an important role in connection with accuracy & exact information. So, I adopted both the methods primary as well as secondary method of data collection. A) Primary Data : Throughout the preparation of the project report, I was in the contact of CFO & other staff of finance department of Paramount Surgimed Ltd. o get the information in connection with the practical working of transaction between the company & banks. B) Secondary Data: I have also collected the information, figures & data in connection with the preparation of project report from Balance-sheet & annual report of Paramount Surgimed Ltd. I have also colle cted the information about cash management, services & Latter of Credit provided by the bank to the company. Along with it I have collected information about the topic from the Internet and also form many of my friends and colleagues who have worked over on the similar kind of projects or who are having a good command over the subject. Sources of Data :- Sources of collection of data for a project report has a very