Section 263 Revision Overturned: PCIT Fails to Prove 8% Commission Rate on Accommodation Entry Firm's Income Unjustifiable.

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....Revision u/s 263 - undisclosed income of the firm - Having arrived at the true nature of assessee's activities of that of an accommodation entry provider, the AO has applied commission rate of 8% on total receipts/transaction value of entries - PCIT has not pointed out how rate of 8% being the commission income so determined by the AO is unsustainable in the eyes of law - Revision order set aside - AT....