Held that there was  Substantial difference in consideration shown on registered sale deed and sale agreement, prima facie belief of AO that income had escaped assessment is enough at stage of reopening and merits of matter are not relevant at said stage.  Reassessment is valid. As regards merits the Tribunal held that  the Assessing Officer  failed to establish the understatement of sale consideration, the onus of which was upon him. The assessee also showed receipt of loans/financial assistance from various parties totalling to Rs. 9.50 lakhs in support affidavits. It was not disputed that the cheque numbers provided therein found a place in the registered sale deed, hence, the fact of making payment by these persons directly to the seller was established. The Assessee was also able to prove the source of the balance Rs. 2.50 lakhs and Rs. 65,100 towards the stamp duty and registration charges. Accordingly, addition u/s 69 is  deleted. (AY 2012-13)