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“fair market value”

Capital GainsSection 55(2)Section 55(2)2,353 judgments

The decision most relied on for fair market value is Sunil Kumar Agarwal v. CIT (372 ITR 83), cited in 159 judgments on BharatTax.

Leading authorities on fair market value

Sunil Kumar Agarwal v. CIT
372 ITR 83 · 2015 · High Court
159
citing judgments

The Assessing Officer is duty-bound to refer the valuation of property to the Departmental Valuation Officer under Section 50C(2) when an assessee disputes the stamp duty valuation or if there is a discrepancy between the actual sale consideration and the guideline value. This reference is mandatory, even if not explicitly requested by the assessee, to ensure a realistic fair market value and avoid injustice.

CIT v. ITC Ltd.
236 Taxmann 612 · 2016 · High Court
108
citing judgments

When computing deduction under Section 80IA, specifically for inter-unit transfer of power, the benefit cannot be claimed based on rates chargeable by distribution licensees to consumers. The deduction must be computed based on the rate fixed by the Tariff Regulation Commission for sale by electricity generating companies.

PCIT v. Chain House International (P) Ltd.
98 Taxmann.com 47 · 2018 · High Court
104
citing judgments

The Assessing Officer cannot arbitrarily reject a share valuation report prepared by an expert using recognized methods like NAV or DCF for the purpose of Section 56(2)(viib) without providing valid reasons to demonstrate its perversity or unreasonableness.

CIT v. Puja Prints
360 ITR 697 · 2014 · High Court
88
citing judgments

The amendment to Section 55A(a) of the Income-tax Act, 1961, which replaced "is less than" with "is at variance" as the condition for referring a valuation to a Departmental Valuation Officer, does not have retrospective effect. Consequently, for periods before July 1, 2012, a DVO reference is invalid if the declared value is not "less than" the fair market value.

Vodafone M-Pesa Ltd. v. PCIT
164 DTR 257 · 2018 · High Court
69
citing judgments

An assessee has the option to choose either the Discounted Cash Flow (DCF) method or the Net Asset Value (NAV) method for share valuation under Section 56(2)(viib) read with Rule 11UA. The Assessing Officer cannot substitute the chosen method or value without identifying a specific error in the assessee's valuation.

Hiaben Jayantilal Shah v. ITO
310 ITR 31 · 2009 · High Court
66
citing judgments

When an assessee presents a registered valuer's report for an asset, the Assessing Officer, if forming an opinion that the value claimed is less than the fair market value, must refer the valuation to the Valuation Officer under Section 55A(a). The AO cannot unilaterally reject the registered valuer's report or resort to Section 55A(b) in such a scenario.

CIT v. Smt. Nilofer I. Singh
309 ITR 233 · 2009 · High Court
55
citing judgments

The full value of consideration for computing capital gains under Section 48 refers to the amount stated in the sale deed and cannot be substituted by the market value or a valuation by the DVO under Section 55A, unless there is evidence that the assessee actually received a consideration in excess of the stated amount.

CIT v. Gillanders Arbuthnot & Co.
87 ITR 407 · 1973 · Supreme Court
51
citing judgments

The "full value of the consideration" for computing capital gains under Section 48 of the Income Tax Act, 1961 (or Section 12B(2) of the 1922 Act), means the price actually bargained for and agreed to by the parties, not the market value of the asset transferred. In a sale transaction involving a price, the market value of the consideration is not relevant.

Judgments citing fair market value

Shri Dilip Manibhai Prajapati, Dholka vs. The ITO, Ward-3(2)(1), Ahmedabad

In the result, the appeal of the assessee is allowed in above terms

ITA 179/AHD/2022[2018-19]Status: DisposedITAT Ahmedabad28 Jun 2024AY 2018-19

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyalassessment Year : 2018-19 Shri Dilip Manibhai Prajapati Vs. The Ito, Ward-3(2)(1) 1, Shitalnath Society Ahmedabad. Opp: Aath Gam Patel Wadi, Saroda Road Kalikund Dhoka 382 225 Pan : Acspp 9801 C

For Appellant: Shri S.N. Divatia, AR, and Shri Samir Vora, AR
Section 250Section 56(2)(x)

case as well as the law, both the lower authorities ought to have referred the matter to DVO for determination of fair market value as on 29/05/2017 and examine the applicability of sec.56(2)(x) in respect of the valuation so made by DVO. 3. Ground no.1, it was stated ... third co-purchaser of the land, who held 5% 5 share in the said land i.e. Shri Piyush Jashubhai Patel and fair market value of this piece of land was found by the DVO to be Rs.2,25,46,000/- as opposed to the actual price for which

Shri Hari Corporation, Ahmedabad vs. The DCIT, Circle-3(1)(2), Ahmedabad

ITA 1720/AHD/2019[2014-15]Status: DisposedITAT Ahmedabad28 Jun 2024AY 2014-15

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar, Accountnat Member 1. Ita No.1719/Ahd/2019 & 2. Ita No.1720/Ahd/2019 (Assessment Years : 2013-14 & 2014-15 Respectively) Shri Hari Corporation The Dy.Cit A/13, Vrundavan Park Society Vs Circle-3(1)2) Viratnagar Road, Odhav Ahmedabad Ahmedabad – 382 415 Pan: Absfs 9846 B अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Vijay H. Patel, Ar Revenue By : Shri Nitin Vishnu Kulkarni, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 13/06/2024 घोषणा क" तार"ख /Date Of Pronouncement: 28/06/2024 आदेश/O R D E R Per Shri Makarand V. Mahadeokar, Am: Both The Captioned Appeals By The Assessee Are Directed Against The Separate Orders Of The Commissioner Of Income Tax(Appeals)-9, Ahmedabad [Cit(A) In Short] Dated 03/10/201 & 04/10/2019 For The Assessment Years (Ays) 2013-14 & 2014-15 Respectively. Since The Common Issues Are Involved In Both The Appeals, These Were Heard Together & Are Being Disposed Of By This Consolidated Order For The Sake Of Convenience.

For Appellant: Shri Vijay H. Patel, ARFor Respondent: Shri Nitin Vishnu Kulkarni, Sr.DR
Section 142Section 142ASection 143(1)Section 144Section 69Section 69ASection 69B

issued by civil engineer is not reliable. 3.1. Therefore, the AO referred the case to the District Value Officer (DVO) to ascertain the fair market value of the work-in-progress. The District Valuation Officer, vide his order under section 142A of the Act, No.2(7)/DVO/2015-16/403 dated ... September-2016, estimated the fair market value of the WIP. The AO issued show-cause notice to the assessee. The AO not satisfied with the reply of the assessee, made an addition of Rs.1,39,61,058/- being difference in the value of work-in-progress and passed an order

Shri Hari Corporation, Ahmedabad vs. The DCIT, Circle-3(1)(2), Ahmedabad

ITA 1719/AHD/2019[2013-14]Status: DisposedITAT Ahmedabad28 Jun 2024AY 2013-14

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar, Accountnat Member 1. Ita No.1719/Ahd/2019 & 2. Ita No.1720/Ahd/2019 (Assessment Years : 2013-14 & 2014-15 Respectively) Shri Hari Corporation The Dy.Cit A/13, Vrundavan Park Society Vs Circle-3(1)2) Viratnagar Road, Odhav Ahmedabad Ahmedabad – 382 415 Pan: Absfs 9846 B अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Vijay H. Patel, Ar Revenue By : Shri Nitin Vishnu Kulkarni, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 13/06/2024 घोषणा क" तार"ख /Date Of Pronouncement: 28/06/2024 आदेश/O R D E R Per Shri Makarand V. Mahadeokar, Am: Both The Captioned Appeals By The Assessee Are Directed Against The Separate Orders Of The Commissioner Of Income Tax(Appeals)-9, Ahmedabad [Cit(A) In Short] Dated 03/10/201 & 04/10/2019 For The Assessment Years (Ays) 2013-14 & 2014-15 Respectively. Since The Common Issues Are Involved In Both The Appeals, These Were Heard Together & Are Being Disposed Of By This Consolidated Order For The Sake Of Convenience.

For Appellant: Shri Vijay H. Patel, ARFor Respondent: Shri Nitin Vishnu Kulkarni, Sr.DR
Section 142Section 142ASection 143(1)Section 144Section 69Section 69ASection 69B

issued by civil engineer is not reliable. 3.1. Therefore, the AO referred the case to the District Value Officer (DVO) to ascertain the fair market value of the work-in-progress. The District Valuation Officer, vide his order under section 142A of the Act, No.2(7)/DVO/2015-16/403 dated ... September-2016, estimated the fair market value of the WIP. The AO issued show-cause notice to the assessee. The AO not satisfied with the reply of the assessee, made an addition of Rs.1,39,61,058/- being difference in the value of work-in-progress and passed an order

Tejonirman Estates Private Limited, Hyderabad vs. Income Tax Officer, Ward-2(4), Hyderabad

In the result, the appeal filed by the assessee allowed for statistical purposes

ITA 598/HYD/2024[2014-15]Status: DisposedITAT Hyderabad27 Jun 2024AY 2014-15

Bench: Shri Manjunatha. G. Hon’Bleassessment Year: 2014-15 Tejonirman Estates Private Vs. The Income Tax Officer, Ward – 2(4), Hyderabad. Limited, Hyderabad. Pan : Aabct9393H (Appellant / Assessee) (Respondent) Assessee By: Shri P. Murali Mohan Rao, Ca Revenue By: Ms. P. Sumitha, Sr.Ar Date Of Hearing: 27.06.2024 Date Of Pronouncement: 27.06.2024

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Ms. P. Sumitha, Sr.AR
Section 43C

make addition towards difference in value. In response, the assessee submitted that particular plot was sold is a distress sale and therefore, fair market value of the property as per the stamp duty valuation cannot be taken for the purpose of Section 43CA of the Act. The Assessing Officer after ... assessment year 2014-15, assessed a sum of Rs.16,87,500/- being difference between sale consideration, as per the registered sale deed and fair market value of the property as per stamp duty valuation under section 43CA of the Income Tax Act, 1961. 3. Being aggrieved by the assessment order

ACIT, Central Circle-2(3), Hyderabad vs. Kavya Boppana, Hyderabad

In the result, the appeal filed by the Revenue is dismissed

ITA 696/HYD/2022[2019-20]Status: DisposedITAT Hyderabad27 Jun 2024AY 2019-20

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

For Appellant: Shri P. Murali MohanFor Respondent: Ms. TH Vijaya Lakshmi
Section 132(4)Section 153ASection 50C

which is applicable from 01.04.2019 relevant to assessment year 2019-20, when inventory is converted into capital asset, then fair market value of the property as on the date of conversion should be treated as profits and gains from business. Therefore, invoked the provisions of Section ... applying the fair market value of the property, department value of the property at Rs.25.81 crores and assessed sum of Rs.6,45,35,000/- being 1/4th share of the assessee under the head income from business and profession. 17.2. Being aggrieved by the assessment order, the assessee carried the matter

ACIT, Central Circle-2(3), Hyderabad vs. Jhansi Rani Boppana, Hyderabad

In the result, the appeal filed by the Revenue is dismissed

ITA 694/HYD/2022[2019-20]Status: DisposedITAT Hyderabad27 Jun 2024AY 2019-20

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

For Appellant: Shri P. Murali MohanFor Respondent: Ms. TH Vijaya Lakshmi
Section 132(4)Section 153ASection 50C

which is applicable from 01.04.2019 relevant to assessment year 2019-20, when inventory is converted into capital asset, then fair market value of the property as on the date of conversion should be treated as profits and gains from business. Therefore, invoked the provisions of Section ... applying the fair market value of the property, department value of the property at Rs.25.81 crores and assessed sum of Rs.6,45,35,000/- being 1/4th share of the assessee under the head income from business and profession. 17.2. Being aggrieved by the assessment order, the assessee carried the matter

ACIT, Central Circle-2(3), Hyderabad vs. Tara Chand Boppana, Hyderabad

In the result, the appeal filed by the Revenue is dismissed

ITA 692/HYD/2022[2019-20]Status: DisposedITAT Hyderabad27 Jun 2024AY 2019-20

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

For Appellant: Shri P. Murali MohanFor Respondent: Ms. TH Vijaya Lakshmi
Section 132(4)Section 153ASection 50C

which is applicable from 01.04.2019 relevant to assessment year 2019-20, when inventory is converted into capital asset, then fair market value of the property as on the date of conversion should be treated as profits and gains from business. Therefore, invoked the provisions of Section ... applying the fair market value of the property, department value of the property at Rs.25.81 crores and assessed sum of Rs.6,45,35,000/- being 1/4th share of the assessee under the head income from business and profession. 17.2. Being aggrieved by the assessment order, the assessee carried the matter

ACIT, Central Circle-2(3), Hyderabad vs. Sarat Gopal Boppana, Hyderabad

In the result, the appeal filed by the Revenue is dismissed

ITA 690/HYD/2022[2019-20]Status: DisposedITAT Hyderabad27 Jun 2024AY 2019-20

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

For Appellant: Shri P. Murali MohanFor Respondent: Ms. TH Vijaya Lakshmi
Section 132(4)Section 153ASection 50C

which is applicable from 01.04.2019 relevant to assessment year 2019-20, when inventory is converted into capital asset, then fair market value of the property as on the date of conversion should be treated as profits and gains from business. Therefore, invoked the provisions of Section ... applying the fair market value of the property, department value of the property at Rs.25.81 crores and assessed sum of Rs.6,45,35,000/- being 1/4th share of the assessee under the head income from business and profession. 17.2. Being aggrieved by the assessment order, the assessee carried the matter

Tara Chand Boppana, Hyderabad vs. ACIT., Central Circle-2(3), Hyderabad

In the result, the appeal filed by the Revenue is dismissed

ITA 646/HYD/2022[2020-21]Status: DisposedITAT Hyderabad27 Jun 2024AY 2020-21

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

For Appellant: Shri P. Murali MohanFor Respondent: Ms. TH Vijaya Lakshmi
Section 132(4)Section 153ASection 50C

which is applicable from 01.04.2019 relevant to assessment year 2019-20, when inventory is converted into capital asset, then fair market value of the property as on the date of conversion should be treated as profits and gains from business. Therefore, invoked the provisions of Section ... applying the fair market value of the property, department value of the property at Rs.25.81 crores and assessed sum of Rs.6,45,35,000/- being 1/4th share of the assessee under the head income from business and profession. 17.2. Being aggrieved by the assessment order, the assessee carried the matter

Kavya Boppana, Hyderabad vs. ACIT., Central Circle-2(3), Hyderabad

In the result, the appeal filed by the Revenue is dismissed

ITA 642/HYD/2022[2020-21]Status: DisposedITAT Hyderabad27 Jun 2024AY 2020-21

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

For Appellant: Shri P. Murali MohanFor Respondent: Ms. TH Vijaya Lakshmi
Section 132(4)Section 153ASection 50C

which is applicable from 01.04.2019 relevant to assessment year 2019-20, when inventory is converted into capital asset, then fair market value of the property as on the date of conversion should be treated as profits and gains from business. Therefore, invoked the provisions of Section ... applying the fair market value of the property, department value of the property at Rs.25.81 crores and assessed sum of Rs.6,45,35,000/- being 1/4th share of the assessee under the head income from business and profession. 17.2. Being aggrieved by the assessment order, the assessee carried the matter

Sarat Gopal Boppana, Hyderabad vs. ACIT., Central Circle-2(3), Hyderabad

In the result, the appeal filed by the Revenue is dismissed

ITA 638/HYD/2022[2019-20]Status: DisposedITAT Hyderabad27 Jun 2024AY 2019-20

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

For Appellant: Shri P. Murali MohanFor Respondent: Ms. TH Vijaya Lakshmi
Section 132(4)Section 153ASection 50C

which is applicable from 01.04.2019 relevant to assessment year 2019-20, when inventory is converted into capital asset, then fair market value of the property as on the date of conversion should be treated as profits and gains from business. Therefore, invoked the provisions of Section ... applying the fair market value of the property, department value of the property at Rs.25.81 crores and assessed sum of Rs.6,45,35,000/- being 1/4th share of the assessee under the head income from business and profession. 17.2. Being aggrieved by the assessment order, the assessee carried the matter

Sarat Gopal Boppana, Hyderabad vs. ACIT., Central Circle-2(3), Hyderabad

In the result, the appeal filed by the Revenue is dismissed

ITA 637/HYD/2022[2018-19]Status: DisposedITAT Hyderabad27 Jun 2024AY 2018-19

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

For Appellant: Shri P. Murali MohanFor Respondent: Ms. TH Vijaya Lakshmi
Section 132(4)Section 153ASection 50C

which is applicable from 01.04.2019 relevant to assessment year 2019-20, when inventory is converted into capital asset, then fair market value of the property as on the date of conversion should be treated as profits and gains from business. Therefore, invoked the provisions of Section ... applying the fair market value of the property, department value of the property at Rs.25.81 crores and assessed sum of Rs.6,45,35,000/- being 1/4th share of the assessee under the head income from business and profession. 17.2. Being aggrieved by the assessment order, the assessee carried the matter

Rajaram Patidar, Bhopal Madhya Pradesh vs. Income Tax Officer 2(4), Hoshangabad Road

Appeal is partly allowed as indicated above

ITA 129/IND/2024[2010-11]Status: DisposedITAT Indore27 Jun 2024AY 2010-11

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2010-11 Rajaram Patidar, Income-Tax Officer, H.No.112, Near Ram Lila 2(4), Maidan, Hoshangabad Road, बनाम/ Ward No. 52-53, Bhopal Vs. Misrod (Assessee/Appellant) (Revenue/Respondent) Pan: Bkapp7594R Assessee By Shri Anil Khabya, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 26.06.2024 Date Of Pronouncement 27.06.2024

Section 143(2)Section 271(1)(c)Section 54B

invalid having been filed beyond statutory time for filing of revised return. Further, the assessee computed capital gain by adopting estimating cost at fair market value as on 01.04.1981 @ Rs. 5 lakh/ hectare but the same was finally upheld by ITAT @ Rs. 1 lakh/hectare in Para 30 of ITAT ... offered by assessee in revised return (+) the difference of Rs. 2,40,998/- relatable to estimation difference of fair market value as on 01.04.1981, represents the amount of impugned addition of Rs. 6,26,256/- surviving in Page 4 of 10 Rajaram Patidar, Misrod vs. ITO, 2(4), Bhopal

Ashish, New Delhi vs. ACIT Circle Intl. Taxation 1(3)(1), New Delhi

The appeal of the assessee is allowed with consequential effects

ITA 2145/DEL/2023[2020-21]Status: DisposedITAT Delhi27 Jun 2024AY 2020-21

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaassessment Year: 2020-21 Ashish, Vs Acit, E-138, Kalka Ji, Circle Int. Taxation 1(3)(1), New Delhi – 110 019. New Delhi. Pan: Ahipg5987B (Appellant) (Respondent) Assessee By : Ms Chinu Bhasin, Ca & Shri Sagar Rajpoot, Advocate Revenue By : Shri Vizay B. Vasanta, Cit-Dr Date Of Hearing : 25.04.2024 Date Of Pronouncement : 27.07.2024 Order Per Anubhav Sharma, Jm:

For Appellant: Ms Chinu Bhasin, CA &For Respondent: Shri Vizay B. Vasanta, CIT-DR
Section 143(3)

computing the same, the AO further did not allow credit of certain payment towards cost of acquisition and considered the sale value as Fair Market Value (FMV) computed by the DVO instead of the actual consideration received by the appellant. 2.3 The CIT(A) granted partial relief to the Assessee

Nabhiraj Ratna Balraj by Legal Heir B.R.Rakesh, Bangalore vs. Income-Tax Officer, Ward-7(2)(1), Bangalore

In the result the appeal of the assessee is allowed

ITA 603/BANG/2024[2016-17]Status: DisposedITAT Bangalore26 Jun 2024AY 2016-17

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2016-17

For Appellant: Ms. Suman Lunkar, CAFor Respondent: Shri Subramanian S., Jt.CIT(DR)(ITAT), Bengaluru
Section 147Section 148Section 234BSection 50C

before any Assessing Officer that the value adopted or assessed or assessable by the stamp valuation authority under sub-section (1) exceeds the fair market value of the property as on the date of transfer; (b) the value so adopted or assessed or assessable by the stamp valuation authority under ... paid by the assessee. Accordingly, we modify the order passed by Ld. CIT(A) and direct the A.O. to ignore the difference between fair market value determined by CIT(A) and the actual consideration as the same is less than 10% of the actual consideration. b) Maria Fernandes Cheryl

Alka Jain, Panchkula vs. DCIT, Central Circle, Karnal

In the result, both the appeals are dismissed

ITA 2961/DEL/2022[2013-14]Status: DisposedITAT Delhi26 Jun 2024AY 2013-14

Bench: Shri Shamim Yahya & Ms. Madhumita Royi.T.A. Nos. 2960 & 2961/Del/2022 (Assessment Years : 2017-18 & 2013-14) Alka Jain Vs. Dcit House No.66, Sector-7, Central Circle Panchkula, Panipat Karnal Haryana – 134 109 Pan : Abopj 0916 B (Appellant) .. (Respondent)

For Appellant: -None-For Respondent: Shri Kanv Bali, Sr. D.R
Section 143(3)Section 153A(1)(b)Section 250(6)Section 56(2)(vii)Section 68Section 69A

Section 56(2)(vii)(c) of the Act is under challenge before us. 9. The impugned addition is on account of difference in fair market value and actual consideration paid by the assessee for purchase of shares. The observation made by Learned AO are as follows: “It was observed ... that the appellant had invested amount of Rs 50,00,000/- in acquiring 125000 shares of JB Rolling Mills @Rs.40/- per share. The fair market value of shares as on 31.03.2017 was computed by the AO as per provisions of Bale 11UA of IT Rules, 1962 at Rs.48.60/- per share

Alka Jain, Panchkula vs. DCIT, Central Circle, Karnal

In the result, both the appeals are dismissed

ITA 2960/DEL/2022[2017-18]Status: DisposedITAT Delhi26 Jun 2024AY 2017-18

Bench: Shri Shamim Yahya & Ms. Madhumita Royi.T.A. Nos. 2960 & 2961/Del/2022 (Assessment Years : 2017-18 & 2013-14) Alka Jain Vs. Dcit House No.66, Sector-7, Central Circle Panchkula, Panipat Karnal Haryana – 134 109 Pan : Abopj 0916 B (Appellant) .. (Respondent)

For Appellant: -None-For Respondent: Shri Kanv Bali, Sr. D.R
Section 143(3)Section 153A(1)(b)Section 250(6)Section 56(2)(vii)Section 68Section 69A

Section 56(2)(vii)(c) of the Act is under challenge before us. 9. The impugned addition is on account of difference in fair market value and actual consideration paid by the assessee for purchase of shares. The observation made by Learned AO are as follows: “It was observed ... that the appellant had invested amount of Rs 50,00,000/- in acquiring 125000 shares of JB Rolling Mills @Rs.40/- per share. The fair market value of shares as on 31.03.2017 was computed by the AO as per provisions of Bale 11UA of IT Rules, 1962 at Rs.48.60/- per share

ACIT, Central Circle- 27, New Delhi vs. Ridgeview Developers Pvt. Ltd., New Delhi

In the result, the appeal filed by the Revenue is dismissed

ITA 7883/DEL/2017[2014-15]Status: DisposedITAT Delhi26 Jun 2024AY 2014-15

Bench: Or At The Time Hearing Of The Appeal.” 3. We Shall Proceed To Dispose Of This Appeal Ground Wise.

Section 37(1)

Sale Deed at the circle rate of Rs. 17,000/- per sq mtr. For the value of Rs. 17,93,00,000/- on fair market value of the plot at that time. Now the assessee has objection for proposed addition of Rs. 17.93 crores ... entire integrated township, there was no question of having preferential location of plot like corner. The assessee submitted that the actual fair market value of said plot is 1.79 cr and requested for the matter to be referred to DVO vide reply dated

Narain Lal Agrawal, Jaipur vs. DCIT Circle 1 Jaipur, Jaipur

ITA 744/JPR/2023[2020-21]Status: DisposedITAT Jaipur25 Jun 2024AY 2020-21
For Appellant: Sh. Tarun Mittal (CA)For Respondent: Sh. A. S. Nehra (Addl. CIT)
Section 143(3)Section 56(2)Section 56(2)(x)

challenged the valuation, the same does not constitute additional evidence. Moreover, as stated above, since Id. Valuation Officer has computed the Fair Market Value of property at Rs.1,86,56,000/- as against Rs.2,28,76,000/- (adopted by Id.AO for making addition), it is thus submitted that addition ... Rs.2,28,76,000- 1,86,56,000/-) deserves to be deleted outrightly. It is further submitted that after considering the Fair Market Value as per Valuation Report, difference in the value of property as taken by assessee and as computed by Id. Valuation Officer comes to Rs.16

Astrazeneca Pharma India Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-1(1)(1), Bangalore

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 284/BANG/2021[2016-17]Status: DisposedITAT Bangalore25 Jun 2024AY 2016-17

Bench: Shri Chandra Poojari & Shri Soundararajan K.

For Appellant: Sri Nikhil Tiwari, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 143(3)Section 37Section 37(1)

specific date in a year and the Assessee recognizes the expenses during the vesting period on a time proportion basis. The fair market value as on the date of grant is recovered by AZUK from the Assessee whenever employees of the Assessee exercises the RSU. The Assessee considers the fair ... Bench in the case of Biocon Ltd vs DCIT [2013] 35 taxmann.com 335 – (Jurisdictional Bangalore Tribunal) which has held that difference in the fair market value of shares and the amount at which shares are issued to employees under ESOP are employee cost. Hence, such expenditure