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(vi) The modus operandi discussed in para (viii) at page 9 of assessment order is based on surmises and conjectures without having material:-

The Id AO under the guise of the modus operandi of the sale of SC/ST land wants to say that the assessee was the real owner of the land which he purchased under agreement to sale and power of attorney. First of all the onus The onus was on the department to prove that the apparent is not real and the said onus was not discharged. Reliance is placed on following decisions:-