Tribunal held that there were cross-deposits and withdrawals. Since the withdrawals from the banks had not been found to have been spent for any other purpose or invested in any immovable or movable property and having regard to the cash flow statement of both the undisclosed bank accounts, the combined peak credit of both the bank accounts needed to be taken to work out the element of undisclosed investments made by the assessee for the undisclosed transactions. From the opening balances in both the banks, this was not the initial year, wherein the assessee had made the undisclosed transaction. However, since this was the assessment year in which the fact of undisclosed bank accounts was discovered, the undisclosed investment needed to be taxed separately. Therefore, the combined peak credit in respect of both accounts needed to be taken to find out the undisclosed investments made by the assessee for the undisclosed transaction in both banks which was  which needed to be added in the hands of the assessee the Assessing Officer was directed to apply the gross profit rate at 8.81 per cent. of the total deposits, therefore, the amount of  towards combined peak credit for investment made by the assessee and the gross profit rate of 8.81 per cent. of total deposits  was sustained and the balance of the addition  was deleted. (AY. 2016-17)