12.5% Addition justified in absence of direct one to one relationship between purchases and sales

RELEVANT EXTRACT OF THE JUDGMENT 2.1 The assessee, Proprietor of M/s. Citizen Sales Corporation, engaged in the business as wholesale dealer of iron and steel, filed her return of income for A.Y. 2009-10 on 25.09.2009 declaring total income of Rs. 1,81,900/-. The return was processed under section 143 (1) of the Income Tax Act, 1961 (in short ‘the Act’). On the basis of the information received, that the assessee was taking bogus bills from certain parties on payment of commission, the Assessing Officer (AO) initiated proceedings under section 147 of the Act for reopening the asses...