DCIT CENTRAL CIRCLE 7 1 MUMBAI, MUMBAI vs. SOYUMM MARKETING PRIVATE LIMITED,, MUMBAI

ITA 4306/MUM/2024Status: DisposedITAT Mumbai04 December 2025AY 2017-18Bench: SHRI SANDEEP SINGH KARHAIL, JUDICIAL MEMBER SHRI PRABHASH SHANKAR (Accountant Member)14 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the Assessing Officer erred in applying an illiquidity discount for the valuation of Non-Cumulative Redeemable Preference Shares when the Net Asset Value (NAV) method was adopted. The SEBI guidelines for mutual funds were also deemed irrelevant.

What were the facts?

The Revenue appealed against the deletion of an addition made under Section 56(2)(viib) of the Income Tax Act. The addition was related to the premium received on the issue of Non-Cumulative Redeemable Preference Shares by the assessee company.

What were the issues?

Whether an illiquidity discount can be applied to the valuation of Non-Cumulative Redeemable Preference Shares when the NAV method is used, and if SEBI guidelines are applicable in such cases.

Which sections of the Income-tax Act were involved?

Section 56(2)(viib)

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Income Tax Appellate Tribunal, “G” BENCH, MUMBAI

Before: SHRI SANDEEP SINGH KARHAILSHRI PRABHASH SHANKAR

For Appellant: Shri Bhupendra Shah
For Respondent: Shri Swapnil Choudhary, Sr.AR

PER SANDEEP SINGH KARHAIL, J.M.

The present appeals by the Revenue arises from the separate impugned orders dated 27.06.2024 and 28.06.2024, passed under section 250 of the Income Tax Act, 1961 (“the Act”) by the learned Commissioner of Income Tax (Appea

The order continues below.

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