Benami proceedings involving a fictitious-name transaction turn...

Benami proceedings involving a fictitious-name transaction turn on cumulative evidence rather than the supplier's failure to file tax returns alone. The alleged supplier's absence from its stated address, unserved notices, inconsistent GST business description, untraceable bank account, and lack of credible proof of supply, delivery, payment, or accounting were identified as sufficient to discharge the initial burden; the appellants did not rebut it. The transaction was therefore treated as benami under Section 2(9)(B). In a fictitious transaction, the routed amount may be regarded as returning to the beneficial owner, permitting attachment in that owner's account rather than requiring attachment only from a benamidar. The provisional attachment and related findings were upheld.

---