Unexplained cash salary addition restored after search material and statement were ignored in deletion without remand verification.

Deletion of the addition for unexplained cash salary was held unsustainable because the appellate authority ignored seized material and a search statement indicating cash salary payments, and deleted the addition without further enquiry or remand verification. The Tribunal found that these relevant facts were not properly dealt with, so the addition was restored. Once the revenue's appeal on that issue succeeded, the cross objection supporting deletion also failed and was dismissed.

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Issues: Whether the deletion of the addition made on account of unexplained salary paid in cash was sustainable in the absence of further enquiry or remand verification, despite seized material and a statement recorded during search indicating cash salary payments.

Analysis: The addition had been made not merely on the basis of loose papers and seized documents, but also on the strength of a statement recorded under search in which cash payment of salary was able. The appellate authority deleted the addition without further verification or remand, and without dealing with the material gathered during search. The Tribunal held that these relevant facts were ignored and that the deletion could not be sustained. The cross objection supporting the deletion was also rendered untenable once the revenue's appeal on the same issue succeeded.

Conclusion: The addition was restored and the revenue succeeded on the issue; the cross objection was dismissed.

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