Advance Pricing Agreements in India: A Revolution in Taxation Law

Double taxation is one of the biggest challenges faced by multinational corporations, especially when the taxable transaction is between associated enterprises. The determination of transfer pricing becomes a bone of contention among the revenue authorities of different countries. One mechanism to counter this problem is to take recourse to „Advance Pricing Agreement‟ (APA). An APA is an arrangement entered into between revenue authority(s) and the taxpayer to determine the transfer pricing in advance. It has a plethora of advantages and procedural benefits over the conventional methods of determination of transfer pricing. APA, which was in existence in many countries for many years, was recently introduced in India. The aim of this paper is primarily to explore the Indian law on APA in the light of the situation prevalent in other countries, and to suggest measures to improve the same. This aim shall be achieved by firstly studying the concepts pertaining to transfer pricing and the problems associated with it, which has led to the emergence of APA. Thereafter, an overview of the Indian APA regime is provided. Further, in order to evaluate the merits and demerits of Indian APA, a comparative study with the law on APA in other countries has been presented, while simultaneously making certain suggestions to make the Indian APA system robust. In the last part of the paper, some suggestions apart from those which were made after analyzing the comparative law have been made. If India improves upon its APA regime by taking a cue from other countries, and by implementing measures such as the creation of safe harbours, better dispute settlement mechanism, easier documentation etc., then the APA will surely bring the much desired revolution in the taxation of multinational corporations

Highway Entrance Ramp Monitoring and Control using Soft Computing Techniques

Highway entrance ramp monitoring and control is used to regularize the flow of traffic entering through the highway entrance ramps. It detects the flow of traffic enter ing through the highway ramp monitoring system and controls the flow of traffic using ramp monitoring and control algorithm. This algorithm employs some soft computing techniques which is a suitable choice due to the imprecise information and the level of inaccuracy in the monitoring data available. The use of AI - based search algorithms to calibrate the parameters of a micro - simulation model or estimate the dynamic demand needed to run the model is an area that has received significant attention from researchers recently. Use of soft computing techniques improves the traffic flow as also increases the efficiency of the traffic system with enhanced control a nd safety

Patch Immunization: Transcutaneous Vaccination for the Cholera Toxin and Optimization of Immunization Cycles

The main point of this analysis was to investigate the diffusion of the cholera vaccination through specific layers of the skin. The antigen was initially modeled through the skin directly to the blood stream. The antigen was also modeled with the presence of a network of Langerhans cells. There was a smooth concentration profile in the skin after one week of patch exposure in the absence of the LC network. However, there was discontinuity in the concentration profile when the LC network was present. The LC network functioned as a large enough sink term that the flux into the bloodstream was virtually zero. Therefore, we concluded that the LC network alone can create a cutaneous immune response. The LC network was enhanced with the presence of Imiquimod, a typical immune response modifier. The modifier increased the activity of the LC network, thus increasing the reaction rate of the LC cells. With Imiquimod there was a sharper discontinuity in the concentration profile at the LC network and the antigen flux into the blood stream is zero. The most effective enhancer tested was the MEMs microneedles, which increased the porosity of the skin and thus the diffusivity of the antigen through the skin. Contour plots of the skin showed absolute diffusion and consumption of the antigen into the LC network, while only partial consumption with the other enhancers tested. Concentration gradients were present in the ultrasonically and photo mechanically enhanced skin because they had weaker enhancing capabilities compared to the MEMs needles. The MEMs needles are the most effective in mass transfer, but are also the most evasive. Vaccines are usually given in cycles to increase the concentration of the antigen in the skin and bloodstream. When the patch was applied to the skin with no enhancer, the maximum concentration was achieved after 2.3 days. However, the maximum concentration in the skin is achieved sooner with the various adjuvants. For example, when the patch is applied with MEMs needles, the maximal concentration is achieved in the skin only after 1.2 hours of exposure. Immunization cycles presented in Glenn et al were simulated to determine the approximate concentration of the antigen at the center of the skin needed for an immune response. This concentration is 0.0038 mol/m^3. Therefore, it was assumed that if the concentration in the skin is close to this value, then an immune response will be initiated. The immunization cycles for each adjuvant used were then optimized

Emergency peripartum hysterectomy: a 3 year review at a tertiary care hospital in Vindhya region of India

Background: Emergency peripartum hysterectomy (EPH), although rare in modern obstetric, still performed as lifesaving surgical procedure to control haemorrhage that is unresponsive to conservative treatment. The objective of this study was to review the incidence, indications, and predisposing factors and associated complications of EPH.Methods: The present study is a retrospective study included 37 women who underwent EPH over a period of 3 year. The records were collected from medical record department.Results: 37 patients underwent EPH during this period making an incidence of 1.1 per 1000 deliveries. Most common indication of EPH in present study was morbidly adherent placenta (MAP) seen in 19 cases (51.4%). 36 patients (97.4%) patient underwent cesarean section at the time of their index pregnancy and 25 out of 37 (67.6%) patient had undergone prior cesarean delivery. 20 (54%) patients underwent total abdominal hysterectomy (TAH) and 17 (46%) patients underwent subtotal hysterectomy (STH). Mean operative time, estimated blood loss, injury to urinary tract, febrile illness and duration of hospital stay was higher in TAH group as compared to STH group but difference was not statistically significant except for estimated blood loss. Maternal mortality was seen in 20% of cases and neonatal mortality was seen in 56.8% of cases.Conclusions: EPH although lifesaving but have devastating consequences. EPH should be performed with a multidisciplinary team approach. Measures should be taken to reduce caesarean section rate

A Correlation of Tumor Budding and Tumor Stroma Ratio with Clinicopathological Factors in Oral Squamous Cell Carcinoma

Background: Squamous cell carcinoma is the most common carcinoma in the head and neck region. Both tumor budding and tumor stroma ratio are being studied in the recent years in various solid tumors for their role as a prognostic marker, however the studies in oral squamous cell carcinoma are limited. Methods: A total of 50 patients of oral squamous cell carcinoma proved histologically were included in the study over a period of 4 months (July 2022-October 2022). Tumor budding(TB) and Tumor stroma ratio (TSR) were evaluated on routine hematoxylin and eosin stained sections and these were correlated with clinicopathological parameters. Statistical analysis was done using Chi-square test and p value <.05 considered significant. Result: The mean age was 52.72 +_ 13.16 and M: F of 7.1:1. Most of the tumors were located on tongue (46%) followed by buccal mucosa (26%), gingivobuccal sulcus (12%) and retromolar trigone (8%). Palate and alveolus were the other sites involved constituting 4% each. Both TB and TSR were found to be significantly associated with grade of the tuumor, lymph node metastasis and size of the tumor. A highly significant correlation was also found between Tb and TSR with a p value <.001. Conclusion: Both TB and TSR can be easily evaluated on routine H&E sections and are highly reproducible and found to be reliable independent prognostic markers in OSCC. Thus, this simple and cost-effective method of prognostification which is currently lacking will help in identifying patients with poor prognosis and thus, individualise the treatment plan. Keywords: Tumor Budding, Oral squamous cell carcinoma, Tumor stroma ratio

Effects of antiplatelet therapy on stroke risk by brain imaging features of intracerebral haemorrhage and cerebral small vessel diseases: subgroup analyses of the RESTART randomised, open-label trial

Background Findings from the RESTART trial suggest that starting antiplatelet therapy might reduce the risk of recurrent symptomatic intracerebral haemorrhage compared with avoiding antiplatelet therapy. Brain imaging features of intracerebral haemorrhage and cerebral small vessel diseases (such as cerebral microbleeds) are associated with greater risks of recurrent intracerebral haemorrhage. We did subgroup analyses of the RESTART trial to explore whether these brain imaging features modify the effects of antiplatelet therapy

Effects of antiplatelet therapy after stroke due to intracerebral haemorrhage (RESTART): a randomised, open-label trial

Background: Antiplatelet therapy reduces the risk of major vascular events for people with occlusive vascular disease, although it might increase the risk of intracranial haemorrhage. Patients surviving the commonest subtype of intracranial haemorrhage, intracerebral haemorrhage, are at risk of both haemorrhagic and occlusive vascular events, but whether antiplatelet therapy can be used safely is unclear. We aimed to estimate the relative and absolute effects of antiplatelet therapy on recurrent intracerebral haemorrhage and whether this risk might exceed any reduction of occlusive vascular events. Methods: The REstart or STop Antithrombotics Randomised Trial (RESTART) was a prospective, randomised, open-label, blinded endpoint, parallel-group trial at 122 hospitals in the UK. We recruited adults (≥18 years) who were taking antithrombotic (antiplatelet or anticoagulant) therapy for the prevention of occlusive vascular disease when they developed intracerebral haemorrhage, discontinued antithrombotic therapy, and survived for 24 h. Computerised randomisation incorporating minimisation allocated participants (1:1) to start or avoid antiplatelet therapy. We followed participants for the primary outcome (recurrent symptomatic intracerebral haemorrhage) for up to 5 years. We analysed data from all randomised participants using Cox proportional hazards regression, adjusted for minimisation covariates. This trial is registered with ISRCTN (number ISRCTN71907627). Findings: Between May 22, 2013, and May 31, 2018, 537 participants were recruited a median of 76 days (IQR 29–146) after intracerebral haemorrhage onset: 268 were assigned to start and 269 (one withdrew) to avoid antiplatelet therapy. Participants were followed for a median of 2·0 years (IQR [1·0– 3·0]; completeness 99·3%). 12 (4%) of 268 participants allocated to antiplatelet therapy had recurrence of intracerebral haemorrhage compared with 23 (9%) of 268 participants allocated to avoid antiplatelet therapy (adjusted hazard ratio 0·51 [95% CI 0·25–1·03]; p=0·060). 18 (7%) participants allocated to antiplatelet therapy experienced major haemorrhagic events compared with 25 (9%) participants allocated to avoid antiplatelet therapy (0·71 [0·39–1·30]; p=0·27), and 39 [15%] participants allocated to antiplatelet therapy had major occlusive vascular events compared with 38 [14%] allocated to avoid antiplatelet therapy (1·02 [0·65–1·60]; p=0·92). Interpretation: These results exclude all but a very modest increase in the risk of recurrent intracerebral haemorrhage with antiplatelet therapy for patients on antithrombotic therapy for the prevention of occlusive vascular disease when they developed intracerebral haemorrhage. The risk of recurrent intracerebral haemorrhage is probably too small to exceed the established benefits of antiplatelet therapy for secondary prevention

Effects of antiplatelet therapy after stroke due to intracerebral haemorrhage (RESTART): a randomised, open-label trial

Background: Antiplatelet therapy reduces the risk of major vascular events for people with occlusive vascular disease, although it might increase the risk of intracranial haemorrhage. Patients surviving the commonest subtype of intracranial haemorrhage, intracerebral haemorrhage, are at risk of both haemorrhagic and occlusive vascular events, but whether antiplatelet therapy can be used safely is unclear. We aimed to estimate the relative and absolute effects of antiplatelet therapy on recurrent intracerebral haemorrhage and whether this risk might exceed any reduction of occlusive vascular events. Methods: The REstart or STop Antithrombotics Randomised Trial (RESTART) was a prospective, randomised, open-label, blinded endpoint, parallel-group trial at 122 hospitals in the UK. We recruited adults (≥18 years) who were taking antithrombotic (antiplatelet or anticoagulant) therapy for the prevention of occlusive vascular disease when they developed intracerebral haemorrhage, discontinued antithrombotic therapy, and survived for 24 h. Computerised randomisation incorporating minimisation allocated participants (1:1) to start or avoid antiplatelet therapy. We followed participants for the primary outcome (recurrent symptomatic intracerebral haemorrhage) for up to 5 years. We analysed data from all randomised participants using Cox proportional hazards regression, adjusted for minimisation covariates. This trial is registered with ISRCTN (number ISRCTN71907627). Findings: Between May 22, 2013, and May 31, 2018, 537 participants were recruited a median of 76 days (IQR 29–146) after intracerebral haemorrhage onset: 268 were assigned to start and 269 (one withdrew) to avoid antiplatelet therapy. Participants were followed for a median of 2·0 years (IQR [1·0– 3·0]; completeness 99·3%). 12 (4%) of 268 participants allocated to antiplatelet therapy had recurrence of intracerebral haemorrhage compared with 23 (9%) of 268 participants allocated to avoid antiplatelet therapy (adjusted hazard ratio 0·51 [95% CI 0·25–1·03]; p=0·060). 18 (7%) participants allocated to antiplatelet therapy experienced major haemorrhagic events compared with 25 (9%) participants allocated to avoid antiplatelet therapy (0·71 [0·39–1·30]; p=0·27), and 39 [15%] participants allocated to antiplatelet therapy had major occlusive vascular events compared with 38 [14%] allocated to avoid antiplatelet therapy (1·02 [0·65–1·60]; p=0·92). Interpretation: These results exclude all but a very modest increase in the risk of recurrent intracerebral haemorrhage with antiplatelet therapy for patients on antithrombotic therapy for the prevention of occlusive vascular disease when they developed intracerebral haemorrhage. The risk of recurrent intracerebral haemorrhage is probably too small to exceed the established benefits of antiplatelet therapy for secondary prevention