Real income principle limits taxation of notional Ind AS entries where no actual receipt or enforceable accrual exists.
Tax computation under the Income-tax Act, 1961 is controlled by statutory provisions and the real-income principle, not merely by Ind AS or ICDS accounting entries. Notional income from discounting refundable security deposits, amortisation of royalty already taxed, or other temporal accounting allocations does not create taxable income without a real receipt or enforceable right to receive. Asset-related grants must follow the statutory actual-cost mechanism, while Ind AS-ICDS borrowing-cost differences are computational timing differences. A procedural delay in certification cannot defeat a substantive research-and-development deduction where underlying approval is undisputed. (AI Summary)

Technical standardisation in digital distribution does not itself establish commercial agency, service PE, or additional profit attribution.
Digital-platform distribution requires a distinction between technical standardisation and commercial control. Exclusivity, standard operating procedures, price limits, and inability to modify software or data feeds may be technical requirements of a single global platform and do not alone establish a Dependent Agent PE. Service PE analysis excludes auxiliary stewardship activities and included services qualifying as technical or consultancy services. Where an Indian distributor contracts, invoices, collects fees, and bears risks in its own name, and receives arm's-length compensation for its functions, risks, and assets, further profit attribution to an assumed PE requires additional functions performed in India. (AI Summary)