24. The Assessing Officer thought fit to estimate 10% 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 @ 10% by the Assessing Officer is 1/3rd of the said benefit,which could be termed as excessive and not a reasonable estimate. The CIT(A),without there being anything on record,thought fit to take the view that the estimate by the appellant at 3% translates to 1% of the benefit derived,which could be termed as too low,and in such circumstances,estimated at 2%,which would translate to about 6.7% of the benefit alleged to have been derived by M/s.PACL India Limited. This is nothing but pure guesswork without there being any material or basis for arriving at the same. The question of law is answered in favour of the assessee and against the Revenue. The impugned order passed by the Income Tax Appellate Tribunal is hereby quashed and setaside.