A search was conducted by revenue in group cases of Dr. AM and S Group of medical stores and connected cases. An agreement for sale of land was found and seized from residence of Dr. RA between AM and LG of one part (as buyers) and assessee, and 4 others of second part (as sellers). Sale consideration mentioned in agreement was higher than registered sale deeds executed subsequently. Assessing Officer brought to tax income in respect of a portion of land and assessed capital gains in hands of assessee and protectively in hands of other sellers, claiming they were benamidars of assessee. Tribunal held that the assessee was owner of land, executor of its sale, and beneficiary of sale proceeds and other sellers were puppets controlled by assessee. Tribunal also observed that all four sellers were closely associated with assessee and lacked capacity to purchase land also found that agreement was valid and its cancellation as well as defect leading thereto, were completely unevidenced. Accordingly revenue was justified in considering assessee as beneficial owner of subject land and assessment of capital gains in assessee’s hands was also justified. (AY. 2008-09)