Benami transaction findings were sustained where deposits and...

Benami transaction findings were sustained where deposits and transfers arose from demonetization-linked routing and accommodation entries, and no credible source of funds or business activity was shown; the fiduciary-capacity exception was rejected because receipt of funds lacked any element of repayment. Creditworthiness and income-tax return analysis of the entities showed inability to account for large cash receipts, and conflicting statements under section 131 were noted. Operative effect: the adjudicating authority's conclusion that the transaction was benami was upheld and the appeal dismissed.