Appeals dismissed; provisional attachment and adjudication under PBPTA upheld as PA applied independent mind under s.26(7)

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....AT dismissed both appeals and upheld the impugned provisional attachment and adjudication orders under the PBPTA. The Tribunal found the Approving Authority applied independent mind, relied on inquiry materials and notes, and concluded the references and orders were within the one-year limitation under s.26(7). The Appellant failed to discharge the evidential burden to prove legitimate consideration for two properties; cash payments and unexplained bank deposits, absence of corroborative agricultural income and missing ITRs warranted inference of non-agricultural/benami dealings. Alleged procedural flaws were characterized as mere surmises. Consequently, the PAO and consequent adjudication were sustained and both appeals were dismissed.....