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If you think about it, the only way Indra could've battled with his brother who had Six Paths Sage Mode is to use Senjutsu of a sort. Also I dont think Indra had Six Paths Sage Mode, since he only inherited his fathers eyes.
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I think its pretty clear that the only way to counter Six Paths Sage Mode is using senjutsu. Thoughts?
EDIT:
Maybe Rinnegan can also counter Gudou Dama and Six Paths Sage Mode. Think about it, Sasuke with Rinnegan was able to touch and pull out the Rinne Black Rods, something Sage Mode users could only do. I could be wrong there.
OR
Indra used the Bijuus to fight against Ashura. Which is kinda reminiscent of Madara using Kurama and Sasuke using all the Bijuu's.
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