Accommodation entry commission estimate restricted to 0.15% where the assessee's declared rate had been accepted earlier.

Commission income from accommodation entries was assessed at 0.15% rather than 1% of turnover, because the assessee had admitted through its director that it provided accommodation entries and its declared commission range of 0.10% to 0.15% had already been accepted in its own case for another year. On that factual basis, the higher 1% estimate was found unjustified, and the commission rate was restricted to 0.15%.

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Issues: Whether the commission income arising from accommodation entries was to be estimated at 1% of turnover or at 0.15%.

Analysis: The assessee had admitted, through its director, to having provided accommodation entries, and the declared commission range of 0.10% to 0.15% had already been accepted in the assessee's own case for another assessment year. In these circumstances, the higher estimate of 1% was not found justified.

Conclusion: The commission rate was directed to be taken at 0.15% and not at 1%, in favour of the assessee.

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