The AO estimated 10 per cent. commission for providing accommodation entries to the tune of Rs. 12,00,02,100. The CIT (A) took the view that the estimation of commission at 10 per cent. by the Assessing Officer is one-third of the benefit, which could be termed as excessive and not a reasonable estimate. The CIT(A)  without there being anything on record, thought it fit to take the view that the estimate by the assessee at 3 per cent. translated to 1 per cent. of the benefit derived, which could be termed too low, and in such circumstances, estimated it at 2 per cent., which would translate to about 6.7 per cent. of the benefit alleged to have been derived by PACL India Ltd.  Tribunal confirmed the addition. On appeal the High Court held that this was nothing but pure guesswork without there being any material or basis for arriving at the same. The Tribunal was not right in law in confirming the addition. (AY. 2011-12)