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9. The Ld. DR on the other hand heavily relied on the orders of the Assessing Officer and Ld. CIT(A) / NFAC.

10. We have heard the rival arguments made by both the sides, perused the orders of the Assessing Officer and Ld. CIT(A) / NFAC and the paper book filed on behalf of the assessee. We have also considered the various decisions cited before us. We find the Assessing Officer in the instant case made addition of Rs.2,17,86,112/- u/s 69A of the Act u/s 69A of the Act as unexplained money on the ground that out of total deposit of Rs.3,23,71,885/- the assessee could explain the source of deposit only to the tune of Rs.1,05,85,773/- and the balance amount was not properly explained. We find the Ld. CIT(A) / NFAC upheld the action of the Assessing Officer, the reasons of which have already been reproduced in the ITA Nos.2591 & 2655/PUN/2024 SA Nos.13 & 14/PUN/2025 preceding paragraphs. It is the submission of the Ld. Counsel for the assessee that during the course of assessment proceedings all the documents were submitted which include the audited financial statements, registration certificate, audit report, bank account statements, cash book written in Marathi language for the entire year and the English translated copy of cash book highlighting / correlating to cash deposit transactions in bank account. However, these documents were neither considered properly by the Assessing Officer nor by the Ld. CIT(A) / NFAC. It is also his submission that the issue of deduction u/s 80P(2)(a)(i) of the Act has been decided by the Co-ordinate Benches of the Tribunal in favour of the assessee. It is also his submission that given an opportunity, the assessee is in a position to substantiate its case by filing the requisite details before the Assessing Officer. Considering the totality of the facts of the case and in the interest of justice, we deem it proper to restore the issue to the file of the Assessing Officer with a direction to grant one final opportunity to the assessee to substantiate its case by filing the requisite details and decide the issue as per fact and law. The assessee is also hereby directed to make its submissions, if any, before the Assessing Officer on the appointed date without seeking any adjournment under any pretext, failing which the Assessing Officer is at liberty to pass appropriate order as per law. We hold and direct accordingly. The grounds raised by the assessee are accordingly allowed for statistical purposes.