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of AT affirmed that seized cash constitutes 'property' under the PBPT and may be subject to benami proceedings. Appellant No.1 was validly proceeded against as a benamidar under ss.2(9)(C) and 2(9)(D) as the cash fell within the statutory definition of benami property; the challenge failed. Appellants Nos.2 and 3 were held not liable as they neither possessed nor claimed ownership of the seized cash. The requirement of prior approval under s.23 was held inapplicable where a show-cause notice had already been issued. The issuance of the SCN and available material sufficed for formation of reason to believe; absence of a fresh independent inquiry or pre-notice disclosure of reasons did not vitiate proceedings.
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