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of The AT affirmed the impugned order and dismissed the appeal, upholding the PAO dated 22.12.2017 under ss.24(4)(a)(i) and 24(4)(b)(i) of the PBPTA. The Tribunal found the Appellant failed to adduce evidence of delivery or transportation of the alleged gold, and discrepancies-invoice shortfall, unexplained credits to a third party's account, post-invoice bank transfers, and transactions confined to the demonetisation period-rendered the dealings suspect. The Appellant's failure to undertake due diligence and the production of a fraudulent PAN, corroborated by investigative statements, led the AT to conclude the receipts totalling approximately Rs.51.7 lakh constituted benami transactions within the meaning of s.2(9A) PBPTA.
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