Cost of used asset couldn't be taken as Nil if cost wasn't enhanced to reduce tax liability

IT : Explanation 3 to section 43(1) could not be applied in respect of acquisition of secondhand plant and machinery by assessee from its sister concerns where firstly, Assessing Officer could not discharge its onus that main objective of transfer of assets was reduction of tax liability and secondly revenue did not discharge its obligation to determine fair value of assets and replace it with cost of acquisition of assessee