Search and seizure was conducted at premises of a land broker wherein certain documents were seized which showed that assessee-dealer cum broker had received certain sum in cash for two land deals with two companies . Assessee submitted that he received a certain sum from those deals but made cash payment to farmers for acquiring land and he claimed for set-off of unaccounted cash payments against unaccounted cash receipts for computing investment in accordance with section 69B of the Act . Assessing Officer held  that assessee had not submitted confirmation from farmers in support of said cash payments and accordingly, he denied claim for set-off and made addition .  Tribunal, allowed claim of assessee holding that subsequent payment should be presumed to be made out of cash available from earlier receipts  .On appeal by the revenue the Court held that the assessee did not furnish any detail or particular about availability of funds from unaccounted land deals during course of assessment proceedings and said receipt had been protectively taxed in hands of assessee and substantive addition had already been made in hands of companies and, thus, such funds were prima facie not available for any further investment made by assessee in his individual land business . Since there was no co-relation between unexplained cash receipts and unexplained cash payments, Assessing Officer had rightly not granted claim of assessee .  High court also held that since there was no evidence on record with regard to payment made by assessee to Shri Govind C.Patel  and  Shri Govind C .Patel  had denied fact of receipt of cash from assessee, there was no need to remand issue back to Assessing Officer, because for unaccounted transactions there cannot be any evidence for either payment or receipts of cash except what is found during course of search and seizure by Department and, consequently, assessee would not be entitled to claim said sum as business expenditure or business loss . (AY. 1985 -86 to 1994 -95 and part of BP  1-4 1995 to 21-9 1995 )