An Indian restaurant was subject to a tax audit, following which a tax assessment was issued to its partners, among others.
In the absence of the restaurant's accounting records, the French Tax Authority (administration ) reconstructed the company's revenue and determined that the company had failed to report certain income, resulting in a tax assessment against the partners.
In order to estimate the restaurant's revenue, the French National Tax Administration (administration ) determined that it could apply—as noted by the Administrative Court of Appeals—"the naan method, under which each meal is accompanied by a naan."
administration . then estimated that it was possible to make fifteen naans with one kilogram of flour. She then calculated the number of meals and multiplied it by an average price.
Before the Administrative Court of Appeals, the taxpayers unsuccessfully attempted to challenge the number of naan breads that could be made from one kilogram of flour or the average price of a meal.
The restatement method has therefore been approved by the judges, as has the tax assessment.
CAA Paris, Nov. 4, 2026, No. 25PA00130
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