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6. Identical grounds have been raised by the assessee in the remaining 2 appeals.

7. The Ld. Counsel for the assessee at the outset did not press ground of appeal No.4 for which the Ld. DR has no objection. Accordingly, the ground of appeal No.4 raised by the assessee is dismissed as 'not pressed'. Ground of appeal No.6 being general in nature, is dismissed.

8. The Ld. Counsel for the assessee while arguing the remaining grounds submitted that the Assessing Officer without considering the nature of credits and subsequent withdrawals from the bank account has made addition of the entire deposits which is not justified. Referring to the decision of Ahmedabad Bench of the Tribunal in the case of Kaushik Pravinchandra Gohel vs. JAO vide ITA Nos.690 to 694/Ahd/2023 order dated 17.04.2024 for assessment years 2015-16 to 2017-18, copy of which is placed at pages 233 to 252 of the paper book, he drew the attention of the Bench to paras 11 to 13 of the order where the Tribunal had ITA Nos.1271 to 1273/PUN/2025 discussed the search carried out at the premises of M/s. Renuka Mata Multi State Urban Co-operative Credit Society Ltd. and has observed that on analysis of cash deposits and withdrawals it was seen that M/s. Renuka Mata Multi State Urban Co- operative Credit Society Ltd. is operating on the basis of typical Angadia Model without maintaining proper documentation regarding identity of persons depositing and withdrawing the cash. Referring to para 21 of the said order, he submitted that the Ahmedabad Bench of the Tribunal under identical circumstances, after considering the report of the Investigation Wing in the case of M/s. Renuka Mata Multi State Urban Co-operative Society Credit Ltd. and various other decisions, adopted the profit rate of 0.25% of the total deposits / credits made in the bank accounts held by the assessee with M/s. Renuka Mata Multi State Urban Co- operative Society Credit Ltd. as reasonable.

11. During the course of arguments, we had requested the Department to furnish a copy of the Investigation Report, on the basis of which the reassessment proceedings were initiated against the assessee so as to facilitate the Bench in adjudicating the issue, which is before the Bench for it's consideration. Accordingly, the Department vide letter dated 15.03.2024, submitted before us the information regarding the report of the Investigation Wing and other related documents.

12. On going through the contents of the report of the Investigation Wing made available to us, we observe that on the basis of search carried out at the premises of Renukamata Society, the Department had observed that the Renukamata Society had opened and was operating several bank accounts, which had been opened in the name of various depositors, many of which were merely name lenders. As per the Investigation Report, most of the depositors were non-filers of Income Tax Returns. Further, as per Investigation Report, the Department had observed that most of such account holders are person of low means and their financial profiling does not correspond to the high volume of cash deposits in their accounts with the Renukamata Society. Further, as per the report, the Department observed that during Financial Year 2012-13, Renukamata Society had made total deposits in the bank account amounting to Rs.45,055 crores. The Department observed that on analysis of cash deposits and withdrawals, it is seen that the society is operating on the basis of typical Angadia Model, without maintaining proper documentation regarding identity of persons depositing and withdrawing the cash. The Department observed that the cash deposits made in these accounts are subsequently transferred to bank accounts of shell entities. The funds are subsequently being remitted abroad by these shell entities for prima facie bogus imports etc. Accordingly, even as per the report of the Investigation Wing, Renukamata Society had roped in various individuals of meagre means to open bank accounts in their names and thereafter, such bank accounts were operated by other persons / real beneficiaries for carrying out various activities viz. remittance of money abroad with falsified documents, payment of custom duty, purchase of bullion etc. Accordingly, even as per the report of the Investigation Wing with the Department, it is evident that the assessee is not the real beneficiary of such banking transactions done in it's bank account. It would be useful to reproduce the relevant extracts of report dated 12.03.2021 for ready reference:-

b) The society has also issued Demand Drafts to various walk-in customers in their branches by splitting the cash received to below Rs. 50,000/- in each instance and without taking any KYC details on record. The investigation carried so far shows that Demand Drafts of substantial amount have been issued by the society, after splitting the amount in such a way that each Demand Draft value is less than Rs.50,000/-.

c) From the analysis of cash deposits and withdrawals, it is seen that substantial amounts of withdrawals made are against deposits made in cash at different branches of the society without proper documentation of identity of persons depositing and withdrawing the cash. Therefore, society is working on the basis of typical Angadia model without maintaining proper documentation.