Prerequisite for show-cause notice: possession of material and recorded reasons permitting notice to alleged Benamidar.

The Initiating Officer may issue a show-cause notice only where he has material collected by the Income-Tax Department in his possession, forms a belief on that material that a specified person holds the property as a Benamidar, and records the reasons for that belief; upon satisfaction of these prerequisites the Officer can serve a notice specifying the property and requiring the person to show cause within the time stated why the property should not be treated as Benami.

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