Appeals dismissed; benami transaction upheld as appellant failed to explain Rs.4.13 crore construction spending and ₹1.1 crore consideration s.24(1) s.63

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....The AT dismissed the appeals, upholding the Adjudicating Authority's finding of a benami transaction. The Tribunal concluded the Respondent established a prima facie case and discharged the onus, shifting evidentiary burden to the Appellant who failed to satisfactorily account for source of funds or legitimate consideration; expenditure of Rs. 4.13 crore on construction while legal title remained with the beneficial owner and minimal consideration post-execution (Rs.1.1 crore) supported the benami finding. The Tribunal held the Provisional Attachment Order valid: notice under s.24(1) was issued, prior approval of the Approving Authority was obtained (albeit before notice), and any procedural defect was saved by s.63, rendering the appeals devoid of merit.....