Accommodation entry commission estimation upheld at 0.26% after comparable-case support and admitted margin evidence.

Commission income from accommodation entry was estimated at 0.26% of turnover, as the higher 0.50% rate was found excessive on the facts. The assessee had admitted engaging in accommodation entry activity, and the director's statement under section 131 ed a margin of 0.10% to 0.15%. A comparable case with similar facts supported adoption of 0.26% as the appropriate commission rate. The estimate was upheld and the Revenue's challenge failed.

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Issues: Whether the commission income from providing accommodation entries was rightly estimated at 0.26% of turnover instead of 0.50%.

Analysis: The assessee had admittedly engaged in the business of providing accommodation entries, and the director's statement recorded under section 131 accepted a margin of 0.10% to 0.15%. The estimation made by the Assessing Officer at 0.50% was found excessive in the facts of the case. Reliance was placed on a comparable case involving similar facts, where 0.26% of turnover was accepted as the appropriate estimate of commission income.

Conclusion: The adoption of 0.26% as the commission rate was upheld and the Revenue's challenge failed.

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