Benami finding upheld; dummy firm cash deposits fix beneficial owner, later s.148 surrender cannot regularize transactions

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....The AT upheld the findings of benami transactions against the appellant and dismissed the appeal. It held that substantial cash deposits in a dummy bank account of a benamidar firm, with no genuine business activity and no supporting sale agreement or documented transaction, established that the appellant was the beneficial owner of the funds. The appellant's plea of ignorance, alleging that her husband operated the bank account, was rejected as legally untenable. The AT further held that subsequent reassessment or surrender of amounts as undisclosed income under s.148 of the Income-tax Act, 1961, could not retrospectively nullify or regularize the earlier benami transactions under the Prohibition of Benami Property Transactions Act, 1988.....