Where the assessee contended that sale transaction executed by her through registered sale deed in favour of her husband is a sham transaction, the onus is on the assessee to prove that it was a sham transaction and it is for the assessee to rebut the presumption that transfer was complete when registered sale deed was executed by assessee and possession handed over to husband of the assessee, by cogent evidence in de novo assessment proceedings before AO.  The AO was directed to allow assessee to file evidences/explanations in her defence and shall give proper and adequate opportunity of being heard to the assessee in accordance with principles of natural justice. (AY. 2008-09)