The onus was upon the Assessing Officer to prove that the assessee received “on money” on sale of the property. The onus to claim that apparent is not real is on one who so claims. When the Assessing Officer requires the assessee to show-cause as to why there is difference between two purchasers and that the assessee offered explanation, no addition can be made simply discarding his explanation. No addition can be made on hypothetical basis or presuming a higher sale price by simply rejecting the contention without cogent reason.