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Tight Blood Sugar Control Doesn't Prevent Strokes in Diabetics: Study
FRIDAY, Sept. 19, 2014 (HealthDay News) -- A six-year study of people with type 2 diabetes found that intensively lowering blood pressure had a long-lasting effect in preventing heart attacks, strokes and deaths. But intensive blood sugar control didn't produce those benefits, the researchers found.
For the study, investigators followed nearly 8,500 participants of a completed diabetes trial. Some participants had had their blood pressure and blood sugar levels strictly controlled, while others had received standard care. The researchers wanted to assess the long-term effects of the intensive control, which ended when the trial concluded.
"One of the points of doing this study was to see if lowering blood sugar for five years might, down the track, translate into protection against stroke and heart attack -- it didn't," said researcher Dr. Bruce Neal, a professor of medicine at the University of Sydney in Australia.
Diabetes is a risk factor for heart disease and stroke. And many diabetics have other risk factors for heart attack and stroke, such as high blood pressure, high cholesterol and excess weight, according to the U.S. National Institute of Diabetes and Digestive and Kidney Diseases.
The original study -- dubbed the ADVANCE study -- "showed clearly that you got these great benefits from blood pressure reduction and you also got some benefit from blood sugar lowering," Neal said.
The unanswered question, Neal said, was if intensive blood pressure and blood sugar control were stopped, would the benefits go away or last.
To find out, they stopped the intensive treatment, but continued to follow the trial participants for an additional 5.9 years.
Over that time, they did find a lasting benefit of intensively lowering blood sugar levels to 6.5 percent in preventing kidney disease, a common complication of uncontrolled diabetes, Neal said. "Probably the five years of treatment we gave them led to changes in the kidney that continued to protect people for many years after."
Among patients who had their blood pressure reduced in the original trial to 135/75 mm Hg -- considered intensive control -- the benefit in reducing the risk of dying from a heart attack or stroke remained, although to a lesser degree, as time went by, Neal said.
"The implication is to continue to take blood pressure drugs if you want to get maximum protection," he said.
The report was published in the Sept. 19 online edition of the New England Journal of Medicine to coincide with presentation of the findings at the annual meeting of the European Association for the Study of Diabetes in Vienna.
Dr. Simon Heller, a professor of clinical diabetes at the University of Sheffield in England, said it isn't surprising that the benefit of intensive blood pressure control lasts beyond the period of intense control, although it may wane as the years go by.
His take on the study? "The main way to reduce heart attacks and strokes in people with type 2 diabetes is to treat increased blood pressure and to reduce cholesterol," he said.
"Blood sugar lowering is not apparently very good at reducing heart attacks or strokes, although it is very effective in reducing the risk of nasty diabetic complications such as diabetic eye disease, nerve damage and most important of all, kidney damage," Heller added.
In the trial, Diamicron MR (gliclazide) -- an older medication -- was the drug used most often to reduce blood sugar. This is in a class of drugs called sulfonylureas.
It's possible, Neal said, that a newer diabetes drug might have a more beneficial effect in preventing heart attacks and strokes.
Dr. Joel Zonszein, director of the Clinical Diabetes Center at Montefiore Medical Center in New York City, agreed. "These newer drugs seem to be much more friendly in terms of heart attacks and strokes," said Zonszein, who was not involved with the study.
Income Tax Department has started sending Reminder by email to those who have not filed their Income tax return for Assessment Year 2014-15. Reminder is based on data available with e-filing website of Income tax India. In the reminder, department has provided a form in which Assessee has to provide the reason for non filing of return. Assessee can choose the option applicable to him and after choosing his option he can click the submit button given in the email :-
Reminder for e-Filing of Income Tax Returns for AY 2014-15
CA Sandeep Kanoi
Income Tax Department has started sending Reminder by email to those who have not filed their Income tax return for Assessment Year 2014-15. Reminder is based on data available with e-filing website of Income tax India. In the reminder, department has provided a form in which Assessee has to provide the reason for non filing of return. Assessee can choose the option applicable to him and after choosing his option he can click the submit button given in the email :-
A format of one such letter is as follows :-
Reminder for Filing of Income Tax Return for Assessment Year 2014-15 – PAN: ABCPJXXXXP
Dear Taxpayer,
This is a gentle reminder for you to file your Income Tax Return for Assessment Year 2014-15. Though, the due date for filing returns for AY 2014-15 is over, there is a provision under the Income Tax Act to file a belated return which may help you to remain compliant with requirements of law. E-filing is simple, easy and convenient as you would have experienced in previous years.
You are, therefore, kindly requested to login to https://incometaxindiaefiling. gov.in and download the free return preparation software with a host of new features to help you in preparing the Income Tax return and submit your return. You can also prepare and submit ITR-1 and ITR-4S online.
Please take some time to browse through all the value – added services offered on the E-filing website that will help you prepare your return accurately and guide you in case of any prior pending items.
Will be submitting ITR shortly.
Already submitted the ITR of AY 2014-15 online.
Already submitted the ITR of AY 2014-15 in paper-mode.
Income is below taxable limit for AY 2014-15.
Needless to mention that the quicker you submit your return and send the signed ITR-V (ITR-Verification) form to CPC, Bangalore, the faster you will get your refund, if any, credited to your bank account. As on 23rd December 2014, over 58.17 lakh refunds have already been issued for AY 2014-15! File early to get your return processed soon.
Regards,
e-Filing Team,
Income Tax Department
e-Filing Team,
Income Tax Department
Transfer pricing: To apply the "Cost Plus Method", there must be a "comparable uncontrolled transaction". The fact that the same product is sold by the assessee to its AEs as well as to third parties does not mean that the two sets of transactions are comparable if the business model, marketing, sales promotion etc is different
The assessee, an Indian company, manufactured chewing gum etc which were sold to the associated enterprises (AEs) and also to independent enterprises (non AEs).The distinction in respect of these transactions with AEs and non AEs is that while the transactions with the AEs are in the capacity as limited risk contract manufacturer, its transactions with the domestic independent enterprises is a business transaction with regular entrepreneurship risks. The assessee applied TNMM to claim that the transactions with the AEs are at arms' length (the TP study report has been criticized by the ITAT as reported here). The TPO rejected TNMM and adopted the "Cost Plus Method" with gross mark up on costs as the profit level indicator, and adopted the internal comparable as gross mark up realized on the domestic sales. In other words, the TPO held that the arm's length price of the products exported to the AEs can be arrived at by adopting the same mark up on costs of such products as was achieved on the domestic sales. This was upheld by the CIT(A). On appeal by the assessee to the Tribunal HELD:
(i) The fundamental input for application of CPM method, next only to ascertainment of historical costs, is ascertainment of the normal mark-up of profit over aggregate of such direct costs and indirect costs in respect of same or similar property or services in a "comparable uncontrolled transaction" or, of course, a number of such "comparable uncontrolled transactions". When compared with CUP method, as against the "price" of a comparable uncontrolled transaction, one has to find out "normal mark up of profit" in a comparable uncontrolled transaction. Whether it is "price" or "normal mark up of profit", the starting point of both these exercises in the CUP and the CPM is finding a "comparable uncontrolled transaction". In order for such comparisons to be useful, the economically relevant characteristics of the situations being compared must be sufficiently comparable. It is only elementary, as is also noted in the OECD Transfer Pricing Guidelines, that "to be comparable means that none of the differences (if any) between the situations being compared could materially affect the condition being examined in the methodology (e.g. price or margin), or that reasonably accurate adjustments can be made to eliminate the effect of any such differences";
(ii) The question that arises is whether the transactions with the AEs can be compared with the sales of similar product to distributors or other entities in the domestic market and particularly in a situation in which not only the market is geographically different but also entire business model is different vis -à-vis transactions with the AEs, inasmuch as the sales in domestic market necessitates substantial expenditure by the assessee for marketing support and sales promotion strategy. In other words, whether "export price of product simplictor, without any marketing support in the related market" can have a "comparable uncontrolled transaction" in "domestic sale price of a product in a situation in which entire marketing function and sales promotion is seller's responsibility". The answer has to be an emphatic 'No'. The two situations, i.e. sale simplictor of a FMCG product for an overseas AE without any costs being incurred on the marketing and sales promotion amongst the end users, and sale of a FMCG product to a domestic independent enterprises with full responsibilities for marketing and sales promotion amongst the end users, are not 'comparable transactions' in the sense that profitability in the latter cannot be a proper benchmark for profitability in the former. It is not only in the marketing and sales promotion that the difference lies, but it extends to the fundamental business model itself particularly as the sale is not to an end user, such as in the cases of plant and equipment etc, but to an intermediary who, in turn, has to sell it to, through yet another tier or tiers of intermediaries, the end user. The sale of products to the non-resident AEs is more akin to contract manufacturing arrangement, while the sale of products to independent enterprises domestically is a regular business entrepreneurial venture. Whether contract manufacturing or not, as long as the business models of sales to AEs and sales to non AEs are different, the transactions under these business models cannot be "comparable transactions" for the purposes of transfer pricing. In the first business model, creation of market in the end users is not the responsibility of the vendor, but in the second business model, it is job of the vendor to create and maintain the market of end users as well. The product may be the same but the FAR profile is materially different and it is this FAR profile which governs the profitability. The basic notions of transfer pricing recognize the impact of FAR profiling on the profitability. When profitability levels in two business situations, due to significant differences in FAR profiles of two situations, are expected to be different, such transactions cease to be comparable transactions for the purposes of transfer pricing analysis;
(iii) On facts, the comparability analysis has been confined to the first segment itself, i.e. characteristic of the property transferred. Undoubtedly, the product comparability is an important factor but its certainly not the sole or decisive factor. The assessee was producing the same products for its AEs as it was producing for independent enterprises but that was all so far as similarities were concerned. The FAR profile was not the same, the contract terms were not the same, the economic circumstances were not the same and the business strategies were not the same. Viewed thus, necessary precondition for application of CPM, i.e. finding normal mark up of profit in comparable uncontrolled transactions, could not have been fulfilled. When uncontrolled transactions were not comparable, the normal mark up on profit on such transactions could not have been relevant either. Accordingly, the authorities below were not justified in holding that the cost plus method was the most appropriate method on the facts of this case. One of the necessary ingredient for application of CPM, i.e. normal mark up of profit in the comparable uncontrolled transactions- whether internal or external, was not available as no comparable uncontrolled transactions were brought on record by the authorities below. What was brought on record as an internal comparable uncontrolled transaction, i.e. manufacturing for the domestic independent enterprises, was uncomparable as the FAR profile was significantly different. Undoubtedly, direct methods of determining ALP, including cost plus method, have an inherent edge over the indirect methods, such as TNMM, but such a preference can come into play only when appropriate comparable uncontrolled transactions can be identified and analysed accordingly. That has not been done in the present case. There is, therefore, no good reason to disturb the TNMM method adopted by the assessee.
PFA.
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