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Whether the show-cause notice under section 24(1) was validly issued and whether the appellant discharged the burden to prove ownership of seized cash: the tribunal held that written "reasons to believe" were recorded prior to and incorporated in the notice as required by the statute and conveyed to the appellant, so the notice was valid; on the substantive issue the appellant failed to produce conclusive, legally admissible evidence (books of account, reliable third-party proof) to establish ownership or source of the cash, rendering explanations inconsistent and after-thoughts-consequence: the impugned order was upheld and no interference granted. - AT
Whether the show-cause notice under section 24(1) was validly issued and whether the appellant discharged the burden to prove ownership of seized cash: the tribunal held that written "reasons to believe" were recorded prior to and incorporated in the notice as required by the statute and conveyed to the appellant, so the notice was valid; on the substantive issue the appellant failed to produce conclusive, legally admissible evidence (books of account, reliable third-party proof) to establish ownership or source of the cash, rendering explanations inconsistent and after-thoughts-consequence: the impugned order was upheld and no interference granted. - AT
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