Projects and related parties
Where contracted margin went between signature and delivery, what the group charged itself along the way, and what the branch in Kochi exposes to two tax authorities at once.
Arkan Technologies · AED · read from the registers, not from Zoho Books
The project register and the related-party arrangements of Arkan Technologies. Every figure in the tables and charts below is read from those two registers, and the books are read only to say how much of the company that is. The books are Zoho Books, kept as summary journals — 222 of them across the 29 months to Aug 2026, over eight accounts and 444 lines. Not one of those lines carries a project: there is no project analysis in the accounting to set these registers against, so the two cannot be reconciled line by line.
The two registers on this screen — the project register and the related-party arrangements — hold no period of their own. They are read as they stand on the day the screen is read, 12 Oct 2026; the month in the bar moves the strip, the three twelve-month drawings and the disclosure test, which read the months the bar names.
The project register and the related-party arrangements of Arkan Technologies, read from the registers; the monthly summary and the two margins from Zoho Books. Every figure on this screen opens its own workings: a project’s margin to what it recognised and what it cost, the register’s totals to every project, an arrangement over a period to its months.
11 reads were made for this screen and every one answered.
Where contracted margin went between signature and delivery. What the group charged itself along the way, and whether that crosses the threshold at which it has to be disclosed. And the branch in Kochi, which is charged nothing at all and is the largest tax question on the screen precisely because no invoice records it.
The related-party arrangements have two legs and no entity of their own, so this company’s position is both what it charged out and what it was charged. Reading one leg reports half a transfer pricing position while presenting it as the whole. The disclosure test is a dirham test: only arrangements struck in dirhams are counted towards it, and both legs count.
The projects table is the chooser: a project’s name opens it in the margin bridge, by ?project= in the address, and the bridge’s head offers the same choice. Where the address names none the screen opens on the project whose cost to date is deepest over what it has recognised, as a share of it, falling back to the largest incomplete contract — Data platform here.
Aug 2026 against Aug 2025, Arkan Technologies, in its own currency. Read from the monthly summary, which is the same source as the statements. Twelve months to Aug 2026 beneath each figure.
The two registers on this screen — the project register and the related-party arrangements — hold no period of their own. They are read as they stand on the day the screen is read, 12 Oct 2026; the month in the bar moves the strip, the three twelve-month drawings and the disclosure test, which read the months the bar names.
The monthly summary of Arkan Technologies, Aug 2026, read from Zoho Books. The same figures as the statements.
Five figures, in the order an accountant reads them: revenue, expenses, gross profit, EBITDA and profit before tax. The strip is the company’s month, as the statements state it, and nothing on the screen restates a figure the strip states.
The project register and the related-party arrangements are kept beside the accounting rather than in it. Nothing in the strip is read from either: the strip is the monthly summary, and the registers are what the panels beneath it draw.
Against the month before — the last month each figure was posted in — rather than the same month a year earlier, which is the movement on the tile.
- Revenue · 0.0%
- Expenses · 0.0%
- Gross profit · 0.0%
- EBITDA · 0.0%
- Profit before tax · 0.0%
- Project milestone lateArkan Technologies · Citizen portal phase 2 · milestone late · 20% completeAED
- Project cost exceeds recognisedArkan Technologies · Citizen portal phase 2 · cost 4,966,000 · recognised 4,920,000AED
- Project not on planArkan Technologies · Point of sale rollout · scope creep · 90% completeAED
- Project not on planArkan Technologies · Managed support · over-serviced · 50% completeAED
- Recharge with no policy heldArkan Technologies · from Arkan Distribution · working capital loan · legs disagreeAED
- Legs disagree on a chargeArkan Technologies · from Arkan Distribution · working capital loan · 1 of 1 monthsAED
Ranked adverse first, then watch, then the tests that came back clean; within a class by the finding’s figure as a share of the company’s revenue for the period, largest first. A balance sheet that does not tie, or a company no rate is held for, outranks any share.
One company, so every row is one of Arkan Technologies’ projects, an arrangement it is party to, or the disclosure test over the year. A project whose cost to date exceeds what it has recognised, a project the register calls milestone late or off plan, and a recharge below the mark-up its policy sets are adverse; a project the register calls anything else but on plan, a recharge with no policy held, an arrangement only one side recognises and a year of charges the threshold makes disclosable are watch. Within a class the rows rank by the finding’s figure as a share of Arkan Technologies’ revenue for Aug 2026.
The two registers on this screen — the project register and the related-party arrangements — hold no period of their own. They are read as they stand on the day the screen is read, 12 Oct 2026; the month in the bar moves the strip, the three twelve-month drawings and the disclosure test, which read the months the bar names.
Tested for Aug 2026: every project’s cost to date against what it has recognised; every project’s state in the register, for one that is late or off plan; every arrangement Arkan Technologies is party to, month by month over the twelve months, against the mark-up its policy sets; every arrangement for both legs recognising it; and the related-party charges in dirhams against the disclosure threshold, over the financial year to date and the last complete year. Adverse, then watch, then clear; within a class by the finding’s figure as a share of the company’s revenue for the period.
FY 2026-27 to date: both legs 6,510,770 against the threshold of 40,000,000, 33,489,230 under the threshold to date. A year that is not over cannot be clear of a threshold on the year, so this carries no row; the year is read again as each month posts.
Six rows at most, in two columns, adverse first: what needs acting on before what needs watching, and a clear row only where a test ran and found nothing. The rest is under Data quality at the foot of the screen, so the face never grows past what a reader can act on in a glance.
Project cost exceeds recognised · Arkan Technologies · 0.56% of Arkan Technologies’ revenue for Aug 2026. Citizen portal phase 2 has cost 4,966,000 to date — effort and the group’s charge — against 4,920,000 recognised, so it has lost 46,000 on what it has delivered, 1% of it. The register holds no budget; cost above what has been earned is the nearest test of over it supports, and it is the margin question.
Project milestone late · Arkan Technologies · 296.8% of Arkan Technologies’ revenue for Aug 2026. The register calls Citizen portal phase 2 milestone late at 20% complete. It holds no milestone date, so which milestone and how late cannot be said here; the word is the register’s own, and the contract of 24,600,000 is what it is late on.
Project not on plan · Arkan Technologies · 106.2% of Arkan Technologies’ revenue for Aug 2026. The register calls Point of sale rollout scope creep at 90% complete, on a contract of 8,800,000. The word is the register’s own; nothing here derives a state from the figures.
Project not on plan · Arkan Technologies · 88.8% of Arkan Technologies’ revenue for Aug 2026. The register calls Managed support over-serviced at 50% complete, on a contract of 7,360,000. The word is the register’s own; nothing here derives a state from the figures.
Recharge with no policy held · Arkan Technologies · 50.7% of Arkan Technologies’ revenue for Aug 2026. Working capital loan charged by Arkan Distribution carries no mark-up policy in any of the 1 months charged in the window, so nothing here can say whether it is charged at arm’s length. Only one side has recognised it, so consolidation cannot rely on it either.
Legs disagree on a charge · Arkan Technologies · 50.7% of Arkan Technologies’ revenue for Aug 2026. Only one side has recognised working capital loan charged by Arkan Distribution in 1 of the 1 months charged in the window. Until both legs agree the arrangement is not at arm’s length and consolidation cannot rely on it.
| Project | Client | State | ContractAED | RecognisedAED | Complete% | Cost to dateAED | Realised marginAED |
|---|---|---|---|---|---|---|---|
| Citizen portal phase 2 | Government authority | milestone late | |||||
| Core banking integration | Regional bank | on plan | |||||
| Payments platform | Saudi bank | on plan | |||||
| Data platform · chosen | Logistics group | on plan | |||||
| Point of sale rollout | Retail group | scope creep | |||||
| Managed support | Healthcare provider | over-serviced | |||||
| Arkan Technologies | 6 projects | 3 of 6 on plan | — |
1 of 6 costs more than earned; 3 not on plan. One row a project: the client, the state the register gives it, the contract, what has been recognised, how far through the work is, what it has cost so far — effort plus the group’s charge — and the margin that survived, in the company’s own currency.
Effort cost carries the subcontractors and the third-party licences as well as payroll: all three are direct cost of the delivery.
Projects whose cost to date exceeds what they have recognised come first, deepest shortfall leading; then the ones the register calls late or off plan; then the rest by contract value. The state column is the register’s own word — on plan, milestone late, scope creep, over-serviced — and nothing here derives one from the figures.
The six projects above recognise AED 39,410,000. Over the 29 months to Aug 2026 the books recognise on 4200 Revenue — technology services, so these six are 20 per cent of it. The rest has no project against it and none is given to it here: these books carry no project analysis, so nothing on this screen can say what that revenue was or what it made, and a residual line called everything else would name a project that does not exist.
The project register of Arkan Technologies, read from Zoho Books.
Margin and completion are proportions of each project’s own contract, so they are comparable across currencies where the money is not.
The reader’s first question is which project, and this is where they choose: a name is an address link, the chosen row says so, and the margin bridge draws that project. The register holds no budget, no milestone date and no month, so the columns are what it holds and what two of them divided give: cost to date is effort plus the group charge, and a project whose cost to date exceeds what it has recognised is over — that is the nearest test of “over” the register supports, and it is the margin question.
The project register and the related-party arrangements of Arkan Technologies. Every figure in the tables and charts below is read from those two registers, and the books are read only to say how much of the company that is. The books are Zoho Books, kept as summary journals — 222 of them across the 29 months to Aug 2026, over eight accounts and 444 lines. Not one of those lines carries a project: there is no project analysis in the accounting to set these registers against, so the two cannot be reconciled line by line.
Citizen portal phase 2, Government authority: milestone contract, milestone late; contract 24,600,000, recognised 4,920,000 (20% of the contract), 20% complete; effort 3,090,000, group charge 1,876,000, cost to date 4,966,000; realised margin (46,000), (1)%; cost exceeds what has been recognised by 46,000.
Core banking integration, Regional bank: fixed contract, on plan; contract 18,400,000, recognised 12,880,000 (70% of the contract), 70% complete; effort 5,290,000, group charge 3,204,000, cost to date 8,494,000; realised margin 4,386,000, 34%.
Payments platform, Saudi bank: fixed contract, on plan; contract 15,200,000, recognised 3,040,000 (20% of the contract), 20% complete; effort 1,976,000, group charge 608,000, cost to date 2,584,000; realised margin 456,000, 15%.
Data platform, Logistics group: tm contract, on plan; contract 13,800,000, recognised 6,970,000 (51% of the contract), 51% complete; effort 3,986,000, group charge 1,090,000, cost to date 5,076,000; realised margin 1,894,000, 27%.
Point of sale rollout, Retail group: fixed contract, scope creep; contract 8,800,000, recognised 7,920,000 (90% of the contract), 90% complete; effort 5,680,000, group charge 1,518,000, cost to date 7,198,000; realised margin 722,000, 9%.
Managed support, Healthcare provider: retainer contract, over-serviced; contract 7,360,000, recognised 3,680,000 (50% of the contract), 50% complete; effort 2,208,000, group charge 674,000, cost to date 2,882,000; realised margin 798,000, 22%.
The register: contracted 88,160,000, recognised 39,410,000, effort 22,230,000, group charge 8,970,000, realised 8,210,000, 21% of what was recognised.
1 of 6 over what it earned; Citizen portal phase 2 1%. One bullet a project: cost to date as the bar against what the project has recognised as the rule, every project on the register, in the signal ink where the cost exceeds it.
Effort cost carries the subcontractors and the third-party licences as well as payroll: all three are direct cost of the delivery.
The project register of Arkan Technologies, read from Zoho Books. Effort cost plus the group’s charge, against what each project has recognised.
The register holds no budget, so nothing here is spend against budget. What it holds is what each project has recognised and what it has cost, and cost above what has been recognised is the one test of “over” the register supports: a project that has cost more than it has earned is losing money on what it has delivered, whatever its contract says it will earn in the end.
Citizen portal phase 2: cost to date 4,966,000, recognised 4,920,000, 46,000 over.
Core banking integration: cost to date 8,494,000, recognised 12,880,000, 4,386,000 in hand.
Payments platform: cost to date 2,584,000, recognised 3,040,000, 456,000 in hand.
Data platform: cost to date 5,076,000, recognised 6,970,000, 1,894,000 in hand.
Point of sale rollout: cost to date 7,198,000, recognised 7,920,000, 722,000 in hand.
Managed support: cost to date 2,882,000, recognised 3,680,000, 798,000 in hand.
Data platform realises 1,894,000; 49% not yet earned.
From contracted to realised on Data platform: what the client agreed to pay, what is signed and not yet delivered, what the people who did the work cost, what the group charged, and what is left. Every step between the two is something that happened, not a balancing figure.
AED. Each step is a claim on the contract between signature and delivery.
55 per cent of what was contracted is taken by work signed and not yet delivered
The project register of Arkan Technologies, read from Zoho Books. Realised margin is recognised revenue less effort cost less the group’s own charge.
The bridge is drawn a project at a time because that is the grain the register holds it at: every step of one project opens its own figure, where the old screen’s company bridge could open nothing. The company’s own bridge is under Detail, in the sentence the old face gave it.
A step is negated exactly rather than by writing a minus in front of the string: a project that has recognised more than it contracted for makes the step negative already.
Data platform: contracted 13,800,000, not yet earned 6,830,000, effort 3,986,000, group charge 1,090,000, realised 1,894,000 (27% of what was recognised).
The register as a whole: contracted 88,160,000, not yet earned 48,750,000, effort 22,230,000, group charge 8,970,000, realised 8,210,000. The steps are totals over the projects below. They open nothing, because a total whose workings showed one project would be a total of something other than what it says — each project in the table opens its own.
1 of 1 past three quarters under 10% margin.
Realised margin against how far through the work is. Bubble area is contract value.
1 of the 1 projects past three quarters complete carry a margin under 10 per cent
The register holds no milestone date, so nothing here is a milestone against its due date: what it holds is how far through each project is and what margin it has realised, and the projects the register calls late or off plan are the ones set apart.
The project register of Arkan Technologies, read from Zoho Books. Both axes are proportions of the project’s own contract.
Whether the projects nearest delivery are the thin ones is the question a scatter answers and a table does not: a project three quarters delivered on a margin under ten per cent has little left to recover it with.
Citizen portal phase 2: 20% complete, (1)% margin, contract 24,600,000, milestone late.
Core banking integration: 70% complete, 34% margin, contract 18,400,000, on plan.
Payments platform: 20% complete, 15% margin, contract 15,200,000, on plan.
Data platform: 51% complete, 27% margin, contract 13,800,000, on plan.
Point of sale rollout: 90% complete, 9% margin, contract 8,800,000, scope creep.
Managed support: 50% complete, 22% margin, contract 7,360,000, over-serviced.
At policy all 12 months; both legs agree.
IT support and infrastructure charged to Arkan Distribution, month by month over the twelve months to Aug 2026: the mark-up the group’s policy sets as one line and the mark-up charged as the other, the gap in the signal ink where the charge falls short of policy. Every one of the 12 months charged is at or above the policy mark-up; both legs agree in every month.
What the group charged itself, at what mark-up, and whether both sides recognise it. Policy and achieved mark-up are held apart.
Read on both legs: 29 monthly charges sold and 30 bought. 30 of those months — Warehouse and logistics recharge, Working capital loan — are recognised by one side only. Until both legs agree the arrangement is not at arm’s length and consolidation cannot rely on it.
The related-party arrangements of Arkan Technologies. Both legs of every arrangement, as each side recorded it. Policy and achieved mark-up are held separately so the distance between them is visible.
Each row is one arrangement — one nature, one counterparty, one direction — and its value opens the months it added, every one of which opens its own workings. The rates beside it open nothing, because a rate is not a total: where every month was charged at the same rate the row states it once, where they differ it states the range, and the month that carries either is in the row underneath it. The note is the same text for every month of an arrangement, so it is written once and sits behind its own cue.
The threshold is tested on both legs together — what this company sold and what it bought — and each leg is printed beside it.
The disclosure test is a dirham test: only arrangements struck in dirhams are counted towards it, and both legs count.
FY 2026-27 to date: Arkan Technologies sold 2,274,684 over 5 monthly charges and bought 4,236,086 over 5; both legs 6,510,770 against the threshold of 40,000,000.
Both legs together leave 33,489,230 under the threshold.
6,510,770 across both legs · 33,489,230 under the threshold to date · the year is not over
The two legs together come to 6,510,770, which leaves 33,489,230 under the threshold of 40,000,000. The headroom is the thing to watch rather than the aggregate: one more arrangement of the size already on this page would cross it.
FY 2025-26: Arkan Technologies sold 5,573,356 over 12 monthly charges and bought 14,416,690 over 13; both legs 19,990,046 against the threshold of 40,000,000.
Both legs together leave 20,009,954 under the threshold.
19,990,046 across both legs · 20,009,954 under the threshold · not disclosable
The two legs together come to 19,990,046, which leaves 20,009,954 under the threshold of 40,000,000. The headroom is the thing to watch rather than the aggregate: one more arrangement of the size already on this page would cross it.
The threshold is a per-period test in the regime, so it is read over the financial year the bar selects — to date where the year is not over — and over the last complete year beside it. Twenty-nine months of register added together was an aggregation the regime does not make, and the finding that rested on it went with it (§5as).
Each leg above opens the arrangements it adds. The line beneath them opens nothing: the arrangements this company is a party to are not one filtered read but two, and a total whose workings listed only one leg would be the very mistake this table exists to show. It is the two figures above it, added.
No account on this trial balance names a balance with another group company
No account on this trial balance names a balance with another group company — not one of its eight — and none of the 270 lines that name a party names one either. The one account it holds against somewhere else is account 2150, Branch current account, and a branch is part of the same company rather than another one. So the 2,274,684 charged out is presumably inside account 4200, Revenue — technology services, and the 4,236,086 borne is presumably inside its three cost accounts, where neither can be identified. Nothing is shown as owed between the companies in either direction.
For a group charging itself 6,510,770 between its own companies, a balance sheet showing nothing between them is the question worth putting. These books cannot answer it either way: they are summary journals, and the charges may well sit inside those captions exactly as above with nothing in the accounting able to distinguish them. That is what makes this the stronger of the two findings — the arrangements the threshold makes disclosable are read from a register, and nothing in the accounting can be pointed at to corroborate either them or the balance they imply.
No two of these are the same question. Each has its own test, its own evidence and its own treatment, and on a statement they would sit under one related-party caption showing one number — which is why what is known about each is printed here rather than summarised into it.
The register is kept beside the accounting rather than in it, so nothing bounds it to what has been posted. The books are posted to Aug 2026 and no arrangement here is charged into a later month, so every month above has a posted month to sit in.
Warehouse and logistics recharge charged by Arkan Distribution: bought · Apr 2024 to Aug 2026 · 29 months · 24,625,162 AED · policy a policy mark-up not held · achieved an achieved mark-up not held · drift no policy to drift from · legs one leg only. Recharged on an allocation key. No benefit test documented and the receiving company has not accrued the corresponding cost — both legs do not agree. No policy rate was ever set for it, so there is no drift to state — absent, not nought, because nought would say it was charged exactly as policy required. Only one side has recognised it, so consolidation cannot rely on it until both legs agree.
IT support and infrastructure charged to Arkan Distribution: sold · Apr 2024 to Aug 2026 · 29 months · 13,409,700 AED · policy 5.0 · achieved 5.0 · drift 0.0 · legs agree. Low value adding intra-group services. Simplified cost plus 5 per cent safe harbour claimed. Documentation held.
Working capital loan charged by Arkan Distribution: bought · Nov 2025 · 1 month · 4,200,000 AED · policy a policy mark-up not held · achieved 0.0 · drift no policy to drift from · legs one leg only. Interest free. An arm's length lender would charge. No policy rate was ever set for it, so there is no drift to state — absent, not nought, because nought would say it was charged exactly as policy required. Only one side has recognised it, so consolidation cannot rely on it until both legs agree.
IT support and infrastructure charged to Arkan Distribution, the twelve months to Aug 2026: Sept 2025: 451,312 AED · policy 5.0 · achieved 5.0 · drift 0.0 · agree; Oct 2025: 446,333 AED · policy 5.0 · achieved 5.0 · drift 0.0 · agree; Nov 2025: 465,016 AED · policy 5.0 · achieved 5.0 · drift 0.0 · agree; Dec 2025: 456,856 AED · policy 5.0 · achieved 5.0 · drift 0.0 · agree; Jan 2026: 459,284 AED · policy 5.0 · achieved 5.0 · drift 0.0 · agree; Feb 2026: 456,212 AED · policy 5.0 · achieved 5.0 · drift 0.0 · agree; Mar 2026: 445,032 AED · policy 5.0 · achieved 5.0 · drift 0.0 · agree; Apr 2026: 464,984 AED · policy 5.0 · achieved 5.0 · drift 0.0 · agree; May 2026: 439,768 AED · policy 5.0 · achieved 5.0 · drift 0.0 · agree; Jun 2026: 449,198 AED · policy 5.0 · achieved 5.0 · drift 0.0 · agree; Jul 2026: 448,093 AED · policy 5.0 · achieved 5.0 · drift 0.0 · agree; Aug 2026: 472,641 AED · policy 5.0 · achieved 5.0 · drift 0.0 · agree.
Group charge 6% of revenue; 12 of 12 months charged.
Revenue from the books and what Arkan Technologies charged the group, month by month over the twelve months to Aug 2026, as two lines on one scale. The charge is read from the related-party arrangements and the revenue from the monthly summary, and nothing says the one sits inside the other.
Revenue by stream cannot be read: the books hold one revenue account, the ledger carries no project analysis, and the project register has no months. Stacking the charge under the revenue would assert that the charge sits inside that account, which the books cannot show.
The monthly summary of Arkan Technologies, the twelve months to Aug 2026, read from Zoho Books. Revenue at each month end; the charge from the related-party arrangements, the same months.
The 2,274,684 charged out over fy 2026-27 to date is presumably inside account 4200, Revenue — technology services, where it cannot be identified: these are summary journals, and nothing in the accounting distinguishes the charge from anything else posted to that caption.
Sept 2025: revenue 7,083,000, charged to the group 451,312.
Oct 2025: revenue 7,083,000, charged to the group 446,333.
Nov 2025: revenue 7,083,000, charged to the group 465,016.
Dec 2025: revenue 7,083,000, charged to the group 456,856.
Jan 2026: revenue 7,083,000, charged to the group 459,284.
Feb 2026: revenue 7,083,000, charged to the group 456,212.
Mar 2026: revenue 7,083,000, charged to the group 445,032.
Apr 2026: revenue 8,287,110, charged to the group 464,984.
May 2026: revenue 8,287,110, charged to the group 439,768.
Jun 2026: revenue 8,287,110, charged to the group 449,198.
Jul 2026: revenue 8,287,110, charged to the group 448,093.
Aug 2026: revenue 8,287,110, charged to the group 472,641.
Net 19.4% and gross 40.0%; net up 2.3 points over 12 months.
Gross margin and net margin, Arkan Technologies, at each of the twelve month ends to Aug 2026, as two lines. A margin is a ratio, and every ratio in this application is computed where the ledger is rather than in the browser: both are read from the ratio definitions, which divide the monthly summary.
The ratio definitions of Arkan Technologies, the twelve months to Aug 2026. Gross margin and net margin at each month end.
Gross margin is what delivery leaves; net margin is what the company keeps after its overhead and its finance cost. The distance between the two lines is the overhead, and a month where they move apart is a month the overhead moved.
Gross margin: Sept 2025 38.8%, Oct 2025 38.8%, Nov 2025 38.8%, Dec 2025 38.8%, Jan 2026 38.8%, Feb 2026 38.8%, Mar 2026 38.8%, Apr 2026 40.0%, May 2026 40.0%, Jun 2026 40.0%, Jul 2026 40.0%, Aug 2026 40.0%.
Net margin: Sept 2025 17.1%, Oct 2025 17.1%, Nov 2025 17.1%, Dec 2025 17.1%, Jan 2026 17.1%, Feb 2026 17.1%, Mar 2026 17.1%, Apr 2026 19.4%, May 2026 19.4%, Jun 2026 19.4%, Jul 2026 19.4%, Aug 2026 19.4%.
| What | AmountAED |
|---|---|
| Borne for the branch | |
| Remitted to the branch | |
| Owed to the branch |
| Step | Branchper 100 | Subsidiaryper 100 |
|---|---|---|
| Indian corporate tax | 35.0† | 22.0† |
| Surcharge and cess | 2.1† | 3.2† |
| Withheld when the profit reaches Dubai | — | 7.5† |
| UAE corporate tax on the same profit | 9.0† | — |
| Credit for the Indian tax already paid | (9.0)† | — |
| Tax on 100 of profit | 37.1† | 32.7† |
The basis is cost plus a mark-up on the branch’s direct cost.† Direct cost is not payroll alone — it carries the subcontractors and the third-party licences bought for the work, and both belong in the base. Leave them out and the branch looks cheaper than it is, so too little profit is attributed to India. Put cost in that Kochi never bore and the Indian tax is overstated while the Dubai profit is understated. Either way the number is wrong in a direction somebody can see.
The comparison is per 100 of profit attributed to Kochi: five routes a branch and a subsidiary take between the Indian charge and the Emirati one, and what each comes to.
Every rate here carries a dagger. They are this application’s reading of the Indian and Emirati rules as they stand, not advice, and no adviser has confirmed them. The books hold no split between Dubai and Kochi, so no profit is attributed here — the comparison is per 100 of whatever the attribution turns out to be.
The three figures in the first band are read from Arkan Technologies’ own ledger: 116 lines naming Kochi branch — Infopark, over 29 months, on 5200 Delivery cost — staff, 1110 Bank — current accounts, 2150 Branch current account. Each opens its own workings down to the voucher line, and none of them carries a dagger, because none of them is assumed.
Nothing below that band is read from the books. Every rate there is a reading of the Indian and Emirati rules as they stand, marked with the dagger wherever it is used.
Kochi is a branch, not a subsidiary, so nothing above prices it: there is no invoice between a company and part of itself.
Under the free zone regime, income attributable to a foreign permanent establishment is excluded from qualifying income — excluded, not exempt. It is also left out of the test that decides whether the free zone status survives, so the status is not what is at risk here. The profit is: it bears 9 per cent† in the UAE while India taxes the same profit, and the relief for that rests on a credit being allowed and on an attribution that has to be defensible to both authorities at once.
The credit line is where the exposure sits. It assumes India’s charge is allowed against the Emirati one on the same profit, and that both authorities accept the same attribution. Where they do not — where India attributes more to Kochi than Dubai concedes — the overlap is taxed twice, and the branch route runs to 46.1† rather than 37.1†.
The subsidiary route costs about 4.4 less per 100, and it replaces an attribution argued after the year end with a transfer price that can be documented before it. What it costs is a second Indian company to file for and a real intercompany invoice to price — which is work the group already does on the arrangements above.
The basis is cost plus a mark-up on the branch’s direct cost.† Direct cost is not payroll alone — it carries the subcontractors and the third-party licences bought for the work, and both belong in the base. Leave them out and the branch looks cheaper than it is, so too little profit is attributed to India. Put cost in that Kochi never bore and the Indian tax is overstated while the Dubai profit is understated. Either way the number is wrong in a direction somebody can see.
No benchmarking study supports the mark-up. That, and not the rate, is the exposure: a rate can be argued from the rules, and a mark-up nobody has benchmarked cannot be argued from anything. Two decisions would settle most of it — commission the study, and establish whether the Dubai company may elect to leave foreign branch profit out of its UAE return at all, which is what the 9 per cent line above is worth. Neither is a filing, and both can be started this quarter.
Indian corporate tax: branch 35.0†, subsidiary 22.0† per 100. A branch is taxed at the foreign company rate. A subsidiary that has elected section 115BAA is taxed at 22.
Surcharge and cess: branch 2.1†, subsidiary 3.2† per 100. Two per cent surcharge on the branch and ten on the subsidiary, and four per cent cess on both.
Withheld when the profit reaches Dubai: branch —, subsidiary 7.5† per 100. A branch remits no dividend, so nothing is withheld. A subsidiary pays one, at the ten per cent the India–UAE treaty allows.
UAE corporate tax on the same profit: branch 9.0†, subsidiary — per 100. Branch profit is excluded from qualifying income and bears the ordinary rate. A dividend from a subsidiary is exempt.
Credit for the Indian tax already paid: branch (9.0)†, subsidiary — per 100. Capped at the UAE tax on the same income, and allowed only if both sides accept the same attribution.
Tax on 100 of profit: branch 37.1†, subsidiary 32.7†. A gap of 4.4 per 100, on rates alone.
2 action · 6 watch · 1 clear.
One company, so every row is one of Arkan Technologies’ projects, an arrangement it is party to, or the disclosure test over the year. A project whose cost to date exceeds what it has recognised, a project the register calls milestone late or off plan, and a recharge below the mark-up its policy sets are adverse; a project the register calls anything else but on plan, a recharge with no policy held, an arrangement only one side recognises and a year of charges the threshold makes disclosable are watch. Within a class the rows rank by the finding’s figure as a share of Arkan Technologies’ revenue for Aug 2026.
The two registers on this screen — the project register and the related-party arrangements — hold no period of their own. They are read as they stand on the day the screen is read, 12 Oct 2026; the month in the bar moves the strip, the three twelve-month drawings and the disclosure test, which read the months the bar names.
Read from Zoho Books. 11 reads were made for this screen and 11 answered. Every figure on this screen opens its own workings, down to the vouchers behind it.
- The group register · register · answered
- The project register · the register · answered
- The related-party arrangements · Arkan Technologies, both sides · answered
- The monthly summary · Arkan Technologies, Aug 2026 and the twelve months to Aug 2026 · answered
- The ratio definitions · Arkan Technologies, the two margins over the twelve months to Aug 2026 · answered
- The ledger · the last posting · answered
- The income accounts · Arkan Technologies, the income accounts · answered
- The ledger · Arkan Technologies, the shape of the ledger · answered
- Parties · Arkan Technologies, the customers on file · answered
- Parties · Arkan Technologies, the branch on file · answered
- The ledger · Arkan Technologies, the branch · answered
Tested for Aug 2026: every project’s cost to date against what it has recognised; every project’s state in the register, for one that is late or off plan; every arrangement Arkan Technologies is party to, month by month over the twelve months, against the mark-up its policy sets; every arrangement for both legs recognising it; and the related-party charges in dirhams against the disclosure threshold, over the financial year to date and the last complete year. Adverse, then watch, then clear; within a class by the finding’s figure as a share of the company’s revenue for the period.
FY 2026-27 to date: both legs 6,510,770 against the threshold of 40,000,000, 33,489,230 under the threshold to date. A year that is not over cannot be clear of a threshold on the year, so this carries no row; the year is read again as each month posts.
- Every project’s cost to date against what it has recognised · ran, found 1
- Every project’s state in the register, for one that is late or off plan · ran, found 3
- Every arrangement Arkan Technologies is party to, month by month over the twelve months, against the mark-up its policy sets · ran, found 2
- Every arrangement Arkan Technologies is party to over the twelve months, for both legs recognising it · ran, found 2
- The related-party charges in dirhams against the disclosure threshold of 40,000,000, over FY 2026-27 to date and over FY 2025-26 — FY 2026-27 to date is under the threshold to date, which is not clear: the year is not over · ran, found nothing
Project cost exceeds recognised · Arkan Technologies · 0.56% of Arkan Technologies’ revenue for Aug 2026. Citizen portal phase 2 has cost 4,966,000 to date — effort and the group’s charge — against 4,920,000 recognised, so it has lost 46,000 on what it has delivered, 1% of it. The register holds no budget; cost above what has been earned is the nearest test of over it supports, and it is the margin question.
Project milestone late · Arkan Technologies · 296.8% of Arkan Technologies’ revenue for Aug 2026. The register calls Citizen portal phase 2 milestone late at 20% complete. It holds no milestone date, so which milestone and how late cannot be said here; the word is the register’s own, and the contract of 24,600,000 is what it is late on.
Project not on plan · Arkan Technologies · 106.2% of Arkan Technologies’ revenue for Aug 2026. The register calls Point of sale rollout scope creep at 90% complete, on a contract of 8,800,000. The word is the register’s own; nothing here derives a state from the figures.
Project not on plan · Arkan Technologies · 88.8% of Arkan Technologies’ revenue for Aug 2026. The register calls Managed support over-serviced at 50% complete, on a contract of 7,360,000. The word is the register’s own; nothing here derives a state from the figures.
Recharge with no policy held · Arkan Technologies · 10.8% of Arkan Technologies’ revenue for Aug 2026. Warehouse and logistics recharge charged by Arkan Distribution carries no mark-up policy in any of the 12 months charged in the window, so nothing here can say whether it is charged at arm’s length. Only one side has recognised it, so consolidation cannot rely on it either.
Recharge with no policy held · Arkan Technologies · 50.7% of Arkan Technologies’ revenue for Aug 2026. Working capital loan charged by Arkan Distribution carries no mark-up policy in any of the 1 months charged in the window, so nothing here can say whether it is charged at arm’s length. Only one side has recognised it, so consolidation cannot rely on it either.
Legs disagree on a charge · Arkan Technologies · 10.8% of Arkan Technologies’ revenue for Aug 2026. Only one side has recognised warehouse and logistics recharge charged by Arkan Distribution in 12 of the 12 months charged in the window. Until both legs agree the arrangement is not at arm’s length and consolidation cannot rely on it.
Legs disagree on a charge · Arkan Technologies · 50.7% of Arkan Technologies’ revenue for Aug 2026. Only one side has recognised working capital loan charged by Arkan Distribution in 1 of the 1 months charged in the window. Until both legs agree the arrangement is not at arm’s length and consolidation cannot rely on it.
- Related-party charges under the threshold · Arkan Technologies · FY 2025-26 · both legs 19,990,046 · threshold 40,000,000 · tested the related-party charges in dirhams against the disclosure threshold of 40,000,000, over FY 2026-27 to date and over FY 2025-26 — FY 2026-27 to date is under the threshold to date, which is not clear: the year is not over