10 Day Magnum Swap - '65 Dart 270

How come there are descrepancies between carb horsepower and fuel injection horse power. From what I read they should make 400-430 with a carb.
I tend to be quite conservative o my HP estimates. Nobody is ever disappointed if they dyno and get 30 hp more than I said but if its 30 HP less....FI and Carb will be the same HP, FI will have more torque sooner due to better air mix.