AT dismissed the appeals and upheld the impugned order. The AT...

AT dismissed the appeals and upheld the impugned order. The AT held the reference and consequent order were within the one-year period under s.24(7) read with s.26(3). The Appellant failed to discharge the onus to rebut benami characterization under s.2(9)(A) of the PBPT Act: explanations and documentary proof of legitimate consideration were held inadequate, sources of funds remained unexplained, and seized disproportionate assets supported inference of illegal income. Reliance on absence of prior approval under s.23 was rejected by application of the retrospective explanation permitting validation. Consequently, properties stood held for the benefit of the beneficial owner and the statutory exception was inapplicable; appeals dismissed.