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Management fees earned through a Cairo hotel permanent...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted allocation method.
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Management fees earned through a Cairo hotel permanent establishment were treated as business profits taxable in UAR and therefore exempt in India under the India-UAR DTAA, with inclusion permitted only for rate purposes. Consistent acceptance of the exemption in earlier and later years supported deletion of the related addition. Indirect common expenditure attributable to exempt dividends remained disallowable only to the extent computed under the consistently accepted income-distribution methodology. For MAT purposes, provision for wealth tax was not an adjustment to book profit because the applicable adjustment covers only income-tax. Reversal of provision for diminution in investment value also did not warrant a book-profit adjustment where the provision had already been added back when created.
Management fees earned through a Cairo hotel permanent establishment were treated as business profits taxable in UAR and therefore exempt in India under the India-UAR DTAA, with inclusion permitted only for rate purposes. Consistent acceptance of the exemption in earlier and later years supported deletion of the related addition. Indirect common expenditure attributable to exempt dividends remained disallowable only to the extent computed under the consistently accepted income-distribution methodology. For MAT purposes, provision for wealth tax was not an adjustment to book profit because the applicable adjustment covers only income-tax. Reversal of provision for diminution in investment value also did not warrant a book-profit adjustment where the provision had already been added back when created.
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