Section 10A adjustments may be made in more than one order where the statute does not require a single composite order.

Section 10A gave the Excess Profits Tax Officer power to make adjustments to counteract avoidance or reduction of excess profits tax liability, but it did not prescribe a single procedural mode for exercising that power. The appealability of the officer's decision showed that the decision had to be embodied in an order, yet nothing in the section required only one composite order. The absence of any legislative direction restricting the officer to one order supported the view that more than one order could be passed, provided they remained within the scope of Section 10A and were made before the officer became functus officio on completion of the assessment under Section 14.

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Issues: Whether the Excess Profits Tax Officer, while exercising power under Section 10A, was confined to passing only one order in respect of the relevant transactions or could pass more than one order during the assessment proceedings.

Analysis: Section 10A conferred power on the officer to make such adjustments as were necessary to counteract avoidance or reduction of excess profits tax liability, but it did not prescribe the procedural mode in which that power had to be exercised. The requirement in Section 10A(3) that the officer's decision be appealable showed that a decision had to be embodied in an order, but it did not restrict the officer to a single order. The use of the indefinite article and the absence of any legislative direction as to a single composite order supported the view that the officer could pass such orders as were appropriate so long as they were within the scope of the section and before he became functus officio on making the assessment under Section 14.

Conclusion: The officer was not restricted to a single order under Section 10A, and the challenge to the two orders failed.

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