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Undisclosed 'on money' receipts are taxable only to the extent of the profit element; the profit rate is fact-specific and must be estimated from project stage, cost structure and seized material, and a 10% profit on gross on money was held reasonable on the facts. ICDS III (construction contracts) does not apply to a contractee/developer in this position, and where the assessee follows project completion/percentage of completion, estimated profit on on money is recognised in the year of execution of the sale deed or on transfer of significant risks and rewards, not necessarily on receipt of the cash.
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