Commission income estimate moderated where property broking was shown but 1% rate lacked corroborative enquiry.

Estimated commission income from brokering immovable property sales was found to be supported by incriminating material showing facilitation of property deals, but the 1% rate was held excessive because no independent enquiry was made with the parties on the actual commission paid or any sharing with other brokers. On that basis, the estimate was moderated to 0.50%, and the addition was sustained only to that reduced extent.

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Issues: Whether the estimated commission income from facilitation of sale of immovable properties at 1% of the sale consideration required reduction.

Analysis: The incriminating material showed that commission had been earned for brokering property deals, but the estimate at 1% was made without independent enquiry from the concerned parties regarding the actual commission paid or the extent of sharing with other brokers. In the circumstances, a lower estimate was considered appropriate to balance the material on record and the absence of corroborative enquiry.

Conclusion: The estimated commission income was reduced from 1% to 0.50%, and the addition was partly sustained in the reduced amount.

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