https://www.taxtmi.com/caselaws?id=801049 Articles 7 and 24 of the India-UAR DTAA treat the Cairo place of management as a permanent establishment, permit taxation of attributable business profits in the UAR, and require exemption of that income in India while allowing rate inclusion. Indirect expenditure relating to exempt income is determined under the accepted allocation methodology after considering expenditure already disallowed. Book-profit computation includes income tax paid or payable but does not extend to wealth-tax provisions. Reversal of a provision for diminution in investment value does not require a further book-profit adjustment where the provision was added back when created and its earlier treatment did not affect taxable income. en-us Fri, 11 Sep 2026 00:00:00 +0530 Thu, 15 Oct 2026 05:44:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=801049 Articles 7 and 24 of the India-UAR DTAA treat the Cairo place of management as a permanent establishment, permit taxation of attributable business profits in the UAR, and require exemption of that income in India while allowing rate inclusion. Indirect expenditure relating to exempt income is determined under the accepted allocation methodology after considering expenditure already disallowed. Book-profit computation includes income tax paid or payable but does not extend to wealth-tax provisions. Reversal of a provision for diminution in investment value does not require a further book-profit adjustment where the provision was added back when created and its earlier treatment did not affect taxable income. Case-Laws Income Tax Fri, 11 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=801049