It will be very simple to prove that he is not using all he is strength, it is enough to know that he is not using the types of haki that give he considerable power
So it's easy to prove he isn't using all of his strength even though he is using his strongest form? Now it's simple to prove he isn't using his strongest attack (which is what you meant saying). But you can't say it's easy to prove someone is holding back.........when they are in their literally strongest form lol
 
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