In Ram Prakash Bhatia vs. DCIT, the ITAT Delhi held that once an assessee is accepted as an accommodation entry operator, the funds routed through bank accounts cannot be treated as his unexplained income. Applying the real income theory and following consistency from earlier years, the Tribunal directed that taxable income be restricted to commission at 0.15% of total credit entries. It rejected the addition of the entire credit turnover under section 68 and also deleted commission on debit entries, holding that taxing both sides would amount to double taxation. The ruling provides significant relief by reaffirming that only commission income is assessable in such cases.