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    <title>2025 (9) TMI 774 - APPELLATE TRIBUNAL UNDER SAFEMA AT NEW DELHI</title>
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    <description>Cash can fall within &quot;property&quot; under the Prohibition of Benami Property Transactions Act when it is tangible movable currency capable of benami treatment. Proceedings could not be sustained against appellants 2 and 3 on these facts because the cash was recovered only from appellant 1. Later ownership claims did not displace the application of section 2(9)(C) and (D) where the original owner denied knowledge and the alleged provider of consideration was not traceable or was fictitious. The Tribunal also treated prior approval and a separate independent investigation as unnecessary on the available record, and found no vitiating prejudice from non-supply of reasons beyond the show-cause notice. Attachment was sustained only against appellant 1.</description>
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    <pubDate>Mon, 08 Sep 2025 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=778285</link>
      <description>Cash can fall within &quot;property&quot; under the Prohibition of Benami Property Transactions Act when it is tangible movable currency capable of benami treatment. Proceedings could not be sustained against appellants 2 and 3 on these facts because the cash was recovered only from appellant 1. Later ownership claims did not displace the application of section 2(9)(C) and (D) where the original owner denied knowledge and the alleged provider of consideration was not traceable or was fictitious. The Tribunal also treated prior approval and a separate independent investigation as unnecessary on the available record, and found no vitiating prejudice from non-supply of reasons beyond the show-cause notice. Attachment was sustained only against appellant 1.</description>
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