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    <title>2026 (4) TMI 459 - ITAT RAJKOT</title>
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    <description>Undisclosed on-money receipts in a real estate project are taxable only to the extent of the profit element embedded in those receipts, not as gross receipts. The estimation must reflect the project&#039;s nature, surrounding facts, past margins and comparable material; on the facts, a 10% addition was treated as fair and reasonable. Taxability was also aligned with the year of execution of the sale deed, not the year of mere receipt, because the assessee&#039;s revenue recognition followed conveyance and ICDS-III was held inapplicable on those facts. The ITAT thus granted partial relief to the assessee and rejected the Revenue&#039;s case on both rate and timing.</description>
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    <pubDate>Fri, 27 Feb 2026 00:00:00 +0530</pubDate>
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      <title>2026 (4) TMI 459 - ITAT RAJKOT</title>
      <link>https://www.taxtmi.com/caselaws?id=789390</link>
      <description>Undisclosed on-money receipts in a real estate project are taxable only to the extent of the profit element embedded in those receipts, not as gross receipts. The estimation must reflect the project&#039;s nature, surrounding facts, past margins and comparable material; on the facts, a 10% addition was treated as fair and reasonable. Taxability was also aligned with the year of execution of the sale deed, not the year of mere receipt, because the assessee&#039;s revenue recognition followed conveyance and ICDS-III was held inapplicable on those facts. The ITAT thus granted partial relief to the assessee and rejected the Revenue&#039;s case on both rate and timing.</description>
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