Accommodation Entry Commission Restricted to 0.5% – Addition Reduced to Actual Involvement

Manish Mansukhlal Maradiya Vs CIT (ITAT Mumbai) Mumbai ITAT partly allowed the assessee’s appeal, holding that commission income from accommodation entries must be restricted to actual transactions and reasonable rate. The Tribunal observed: AO estimated commission @ 5% on ₹4.60 crore, assuming involvement in 8 entities However, from the statement recorded u/s 131 (page 4–5): Assessee admitted involvement only in 3 entities Accepted accommodation entries of ₹1.20 crore only No material was brought to link assessee with remaining 5 entities The ITAT held: Addition cannot be made o...