Undervaluation not established where sales to unrelated buyers matched connected-party prices, and rectification was refused.

Rectification of the final order was sought on the ground that the finding of no undervaluation was unsupported. The record showed sales of the same product to unrelated buyers at the same price as sales to a connected concern, and invoices corroborated that position. Revenue's objection relied on higher-priced purchases from other parties, but that factual basis did not establish undervaluation. No apparent error warranting rectification was shown, so the application was rejected.

---

---

Issues: Whether the earlier final order required rectification on the ground that the finding of no undervaluation of goods was and unsupported.

Analysis: The application sought correction of the earlier finding that there was no undervaluation. The record showed that the assessee had sold the same product to unconnected buyers at the same price as sales made to the connected concern, and documentary evidence in the form of invoices also supported that position. The objection raised by the Revenue was based on a different factual premise, namely higher-priced purchases from other parties, which by itself did not establish undervaluation.

Conclusion: No ground for rectification was made out and the application was rejected.

---