Income Tax Case: Excessive Commission to Shareholding Employee Disallowed Due to Unrealistic Rate Difference with Non-Related Parties.

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....Disallowance of commission paid - excessive expense on commission - the average rate of commission paid by the assessee to others in respect of rice was 20, but rate of commission paid to the employee, holding 17.05% shares in the company, was at 215 and the difference of rate of commission is at 195%. The said deference is not only excessive and the same is unrealistic in the market. The AO has rightly made the comparison of the average rate of commission paid by the assessee himself in the case of non related parties to come to the said conclusion. - AT....