The assessee was found, on the basis of DRI investigation, to be engaged in providing accommodation entries through bogus purchase, sale and loan transactions. The AO rejected the books under section 145(3) and estimated commission income at 0.5% of the aggregate of purchases and sales turnover. The CIT(A) reduced the commission to 0.05% of the aggregate of purchases and sales and estimated commission on loan transactions separately. The  Tribunal, following its earlier decision in Sanjay Kumar Choudhary (HUF) v. ACIT (ITA No. 1367 /Ahd /2017 dt 29-12 2021(Ahd)(Trib)   held that commission in the case of accommodation entry providers is to be estimated only on the sales turnover and not on both purchases and sales, since profit is linked with sales. Accordingly, it directed the AO to estimate commission income at 0.05% of the total sales turnover in the case of all the assessees. The technical ground challenging limitation was treated as not pressed. Assessees’ appeals were partly allowed and Revenue’s appeals were dismissed. [AY. 2018-19]