“valuation of shares”

Special Rate ProvisionsRule 11UARule 11UA508 judgments

TECHPARK HOTELS PVT LTD,GURGAON vs. ADDI. CIT SPECIAL RANGE-9, NEW DELHI

In the result, the appeal filed by the Assessee is allowed

ITA 9450/DEL/2019[2015-16]Status: DisposedITAT Delhi20 Mar 2026AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumartechpark Hotels Pvt. Ltd., Addl. Cit, Ground Floor, Central Wing, Special Range-9, Thapar House 124, Janpath, Vs. New Delhi. New Delhi-110001. Pan-Aabce5833H (Appellant) (Respondent) Assessee By Shri Neeraj Jain, Adv. & Shri Tavish Verma, Adv. Ms. Harpreet Kaur Hansra Sr. Dr Department By Date Of Hearing 20.01.2026 Date Of Pronouncement 20.03.2026 O R D E R Per Vimal Kumar, Jm: The Appeal Filed By The Assessee Is Against Order Dated 11.09.2019 Of The Learned Commissioner Of Income Tax (Appeals), New Delhi [Hereinafter Referred To As ‘The Ld. Cit(A)’] Passed U/S 250 Of The Income Tax Act, 1961, [Hereinafter Referred To As ‘The Act’] Arising Out Of Assessment Order Dated 30.12.2017 Of The Ld. Assessing Officer U/S 143(3) Of The Act For Assessment Year 2015-16. 2. Brief Facts Of The Case Are That The Assessee Filed Return Declaring Loss Of Rs.23,06,28,106/- On 30.11.2015. Notice U/S 143(2) Dated 22.09.2016 Was Issued. Notices U/S 142(1) Were Issued. Sh. Nikhil Agarwal & Shri Nirmal Malpani, Ca Appeared & Filed Details. On Completion Of Proceedings, Ld. Ao Vide Order Dated Techpark Hotels Pvt. Ltd. Vs. Acit

Section 142(1)Section 143(2)Section 143(3)Section 154Section 234DSection 250Section 56(2)Section 56(2)(viib)

appellant. 4. That the CIT(A) erred on facts and in law in rejecting the Discounted Cash Flow ['DCF'] method for valuation of shares and in considering the Net Asset Value ['NAV'] method without appreciating that the FMV of the shares was computed keeping in view the future growth ... appreciate that NAV method cannot be taken as the price at which transaction would take place in case of going concern and moreover, valuation of share is, in essence, a prophesy as to the future and must be based on facts available about future at the required date of valuation

SHALBY LTD.,AHMEDABAD vs. THE DY.CIT, CIRCLE-4(1)(1), AHMEDABAD

In the result, the appeal of the assessee is dismissed

ITA 1005/AHD/2023[2015-16]Status: DisposedITAT Ahmedabad16 Mar 2026AY 2015-16

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2015-16

For Appellant: Shri Aseem Thakkar, A.RFor Respondent: Shri R P Rastogi, CIT-D.R

Section 143(3)Section 56(2)(ib)Section 56(2)(vii)Section 56(2)(viib)Section 68

reply in the name of investor company. Thus, the CIT(A) has dismissed the appeal of the assessee stating therein that the valuation of shares was not according to Rule 11UA of the Income Tax Rules, 1962 and has not proved the genuineness of the transaction and confirmed the addition ... investor company. The appellant has failed to refute the said finding of the AO. As regard the claim of the appellant regarding the valuation of shares being in accordance with Rule 11UA of the Income-tax Rules 1962, the AO has given a detailed finding on the same in paras

ASIRVAD MICRO FINANCE LIMITED,ANNA SALAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE -1(1), CHENNAI

The appeal of the assessee is partly allowed

ITA 1139/CHNY/2025[2015-16]Status: DisposedITAT Chennai10 Mar 2026AY 2015-16

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.1139/Chny/2025 िनधा$रण वष$ /Assessment Year: 2015-16

For Appellant: Mr. P.R. Prasanna Varma, FCAFor Respondent: Mr. Bipin C.N., CIT

Section 250Section 56(2)(viib)

valuation and why the difference cannot be added as addition u/s. 56(2)(viib) of the Act. The assessee submitted that the valuation of shares are based on estimation of future cash flows and DCF method is as per Rule 11A of income tax Rules. The assessee further submitted that ... also contending that the actual profits of the assessee is far more than what is projected under DCF method and accordingly the valuation of shares is fully justified. The contention of the Revenue is that the valuation report is an afterthought which is obtained after two years of actual issue

ASCENTECH ENGINEERING SOLUTIONS PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE 1(1), HYDERABAD

In the result, appeal of the Assessee is allowed

ITA 1686/HYD/2025[2017-18]Status: HeardITAT Hyderabad06 Mar 2026AY 2017-18

For Appellant: MS Sree Lekha, AdvocateFor Respondent: Sri Mathivanan S A, Sr. AR

Section 56(2)(vii)Section 56(2)(viib)

shares of the company. In view of the\nabove we hold that the action of the AO by substituting the method for\nthe valuation of shares which was subsequently upheld by the learned\nCIT (A) is contrary to the provisions of law and therefore the same is not\nsustainable.\"\n12.3

INCOME TAX OFFICER, WARD-9(1), KOLKATA, KOLKATA vs. LITTLESTAR SECURITIES PRIVATE LIMITED, KOLKATA

In the result, the appeal of the Revenue is dismissed

ITA 694/KOL/2025[2012-13]Status: DisposedITAT Kolkata06 Mar 2026AY 2012-13

Section 143(3)Section 144BSection 254Section 68

appear commercially improbable to the Revenue. Equating \"traceable\ninvestors\"with \"phantom entities\" is a leap in logic that cannot be countenanced.\nFurthermore, the valuation of shares is a matter of commercial wisdom. Unless the\nRevenue proves a \"live link\" showing that the funds originated from the assessee's own\ncofers

NAVKAR WOLLENS PRIVATE LIMITED,BIKANER vs. ACIT CIRCLE-3, BIKANER

In the result, the appeal of the assessee is allowed

ITA 670/JODH/2025[2014-15]Status: DisposedITAT Jodhpur26 Feb 2026AY 2014-15

Bench: Dr. Mitha Lal Meena, Hon’Ble & Shri Sudhir Pareek, Hon’Blenavkar Woollens Private Ltd. Assistant Commissioner Of Rani Bazar, Bikaner, H.O. Income Tax, Circle – 3 Bikaner, Bikaner Bikaner - 334001 Pan No. Aabcn 9287 G Assessee By Shri Rajendra Jain, Advocate & Smt. Raksha Birla, Ca (Physical) Revenue By Smt. Runi Pal, Cit-Dr & Shri Lalit Kumar Bishnoi, Addl. Cit-Dr (Virtual) Date Of Hearing 29.01.2026. Date Of Pronouncement 26.02.2026. Order Dr. Mitha Lal Meena, A.M.: This Appeal Is Filed By Assessee Against The Order Of National Faceless Appeal Centre Delhi [Hereinafter Referred To As Nfac/Cit(A)] Dated 30.07.2025 With Respect To Assessment Year 2014-15 Challenging Therein Sustaining The Addition Of Rs. 2,34,04,480/- On Account Of Difference Between The Fair Market Value & The Issue Price Of The Equity Shares By Questioning The Method Of Valuation.

Section 144Section 147Section 56(2)(viib)

coordinated Jodhpur Bench has upheld DCF method of valuation adopted by assessee by observing that the assessee has taken the DCF method for valuation of shares and explained to the satisfaction of Assessing Officer under Rule 11UA of Income Tax Rules. Further going through the relevant Sections and Rules, Tribunal

CHITRAKOOT TRADELINE PRIVATE LIMITED,KOLKATA vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

In the result, the appeal of the assessee is allowed

ITA 193/KOL/2025[2012-13]Status: DisposedITAT Kolkata26 Feb 2026AY 2012-13

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Chitrakoot Tradeline Private Limited National Faceless Assessment C/O Agarwal Vishwanath & Centre, Associates, 2Nd Floor, E-Ramp, Jawaharlal Vs. 133/1/1A, S.N. Banerjee Road, Nehtru Road, New Delhi-110003 Pushkal Bhawan, 3 Rd Floor, Kolkata-700103, West Bengal (Appellant) (Respondent) Pan No. Aabcc3130H Assessee By : S/Shri Deep Agarwal & Shubhankar Ghosh, Ars Revenue By : Shri Santanu Ghosh, Dr Date Of Hearing: 22.01.2026 Date Of Pronouncement: 26.02.2026

For Appellant: S/Shri Deep Agarwal &For Respondent: Shri Santanu Ghosh, DR

Section 142(1)Section 143(3)Section 144BSection 68

creditworthiness. Genuineness of the Transactions: The appellant's claim that the share premium was justified by potential future growth lacks documentary support. The valuation of shares appears arbitrary and not based on financial fundamentals or market conditions. Judicial precedents, such as those cited by the AO, support the view that

ACIT CENTRAL CIRCLE 2(3), AHMEDABAD vs. INTAS PHARMACEUTICALS LIMITED, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

ITA 1842/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2016-17

Bench: Ms. Suchitra R. Kamble & Shri Narendra Prasad Sinhaasst. Commissioner Of M/S. Intas Pharmaceuticals Ltd., Vs. Income-Tax, Corporate House, S.G. Highway, Central Circle 2(3), Nr. Sola Bridge, Thaltej, Ahmedabad Ahmedabad-380 054 [Pan : Aaaci 5120 L] (Appellant) .. (Respondent) Appellant Represented By : Shri Sher Singh, Cit (Dr) Respondent Represented By: Shri S. N. Soparkar, Sr. Advocate & Ms. Urvashi Sodhan, Ar Date Of Hearing 07.01.2026 Date Of Pronouncement 24.02.2026 O R D E R Per Ms. Suchitra R. Kamble:-

Section 250

that, DCF method adapted in the valuation report to value equity of M/s Intas Lifesciences Pvt. Ltd., was not the appropriate method of valuation of shares, as entire cash flow of M/s Intas Lifesciences Pvt. Ltd is from the assessee company and also in comparable company method, comparable companies have

INDUTCH COMPOSITES TECHNOLOGY PRIVATE LIMITED,VADODARA vs. DEPUTY COMMISSIONER, CIRCLE 1(1)(1), VADODARA

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

ITA 2004/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad18 Feb 2026AY 2014-15

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI SIDDHARTHA NAUTIYAL (Judicial Member)

For Appellant: Shri Nishit Shah, ARFor Respondent: Shri C Dharani Nath, Sr.DR

Section 250Section 56(2)

assessee contended that the order passed by the authorities below was in the contravention with the provisions of law, since, the assessee’s valuation of shares was rejected without assigning any proper reasons and valuation was done by the AO on an arbitrary basis in contravention of the method prescribed

SECUREINTELI TECHNOLOGIES PVT. LTD.,COIMBATORE vs. DCIT, CORPORATE CIRCLE-1,, COIMBATORE

The appeal of the assessee is allowed for statistical purposes

ITA 3005/CHNY/2025[2022-23]Status: DisposedITAT Chennai17 Feb 2026AY 2022-23

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.3005/Chny/2025 िनधा"रण वष" /Assessment Year: 2022-23

For Appellant: Mr.N.V.Narayanan, AdvocateFor Respondent: Mr. Bipin C.N, CIT

Section 250Section 56(2)(viib)

premium of Rs.270.50/share to M/s.Accel Limited. The Assessing Officer (AO) called on the assessee to furnish the valuation report in support of the valuation of shares. Since the assessee did not furnish any further details, the AO completed the assessment by adding the entire premium amount as addition u/s.56

KARADI PATH EDUCATION COMPANY PRIVATE LIMITED,CHENNAI vs. COMMISSIONER, CHENNAI

In the result the appeal of the assessee is allowed

ITA 1848/CHNY/2025[2018-2019]Status: DisposedITAT Chennai17 Feb 2026AY 2018-2019

Section 143(3)Section 56(2)(vii)Section 56(2)(viib)

failed to appreciate that DCF\nmethod is essentially based on projections which cannot be compared with\nactuals for the purpose of valuation of shares. The AO failed to appreciate that\nthe fairness of assumptions underlying the estimates are of vital importance\nthan any comparison with actual performances when the benefit ... case the Value as on\n02.09.2015 is compounded at that rate from the previous date of valuation to\nthe current date of valuation, the Share value would have been Rs.3,276.46\n(2192.7*1.2224*1.2224). Whereas the Share Value as on 31.07.2017 as per\nValuation report dated 19.09.2017 is Rs.3

SONICA SACHDEVA TH THE LEGAL HEIR DEEPAK SACHDEVA,GHAZIABAD vs. ACIT, GHAZIABAD

In the result, the appeal filed by the assessee is partly allowed

ITA 5051/DEL/2025[2022-23]Status: DisposedITAT Delhi13 Feb 2026AY 2022-23

Bench: Shri Mahavir Singh, Hon’Ble & Shri S. Rifaur Rahman, Hon’Bleasstt. Year : 2022-23 Sonica Sachdeva Through The Legal Vs. Acit, Circle 2(1)(1), Heir Deepak Sachdeva, Ghaziabad 6042, Ats Advantage, Ahinsa Khand, Indrapura, Ghaziabad, Up (Pan: Bfzpk7879E) (Appellant) (Respondent) Appellant By : Shri A.K. Khurana, Ca Respondent By : Ms. Ankush Kalra, Sr. Dr.

For Appellant: Shri A.K. Khurana, CAFor Respondent: Ms. Ankush Kalra, Sr. DR

Section 143(3)Section 69A

recalculated the indexed cost of Rs. 14,10,142/- as unexplained money u/s. 69A of the Act by changing the valuation of shares without any basis. We find that AO has exceeded this jurisdiction in recalculating the value without any basis. In terms of above, we direct

M/S STANCE CONSUMER ELECTRONICS PRIVATE LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CC-32, DELHI

In the result appeal of the assessee for AY 2017-18 in ITA No

ITA 2792/DEL/2025[2017-18]Status: DisposedITAT Delhi13 Feb 2026AY 2017-18

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos.2791 & 2792/Del/2025 (Assessment Yearss 2016-17 & 2017-18)

Section 143(3)Section 147Section 148Section 250Section 68

para 8 of the order observed that has received premium of Rs.1,45,00,000/- and no valuation report was filed for valuation of shares of M/s. Prominent Agencies Pvt. Ltd. at Rs.300/- per shares. In case the AO has doubts about the value of the shares sold

M/S STANCE CONSUMER ELECTRONICS PRIVATE LIMITED,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CC-32, DELHI

In the result appeal of the assessee for AY 2017-18 in ITA No

ITA 2791/DEL/2025[2016-17]Status: DisposedITAT Delhi13 Feb 2026AY 2016-17

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos.2791 & 2792/Del/2025 (Assessment Yearss 2016-17 & 2017-18)

Section 143(3)Section 147Section 148Section 250Section 68

HOLLIS VITRIFIED PRIVATE LIMITED,MORBI, GUJARAT, INDIA vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX - 1, RAJKOT, RAJKOT, GUJARAT, INDIA

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

ITA 363/RJT/2024[2018-19]Status: DisposedITAT Rajkot12 Feb 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 363/Rjt/2024 (Assessment Year: 2018-19) (Hybrid Hearing) Hollis Vitrified Pvt. Ltd. Vs. The Pr. Commissioner Of Income Revenue Survey No. 756/P1/P1/P1, Opp. Tax-1, Rajkot Antique Granito, Ghuntu,-Lakhdhirpur Road, Morbi (Gujarat)-363642 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacch5628Q (अपीलाथ"/Appellant) (""थ"/Respondent)

For Appellant: Shri Fenil H. Mehta, Ld. ARFor Respondent: Shri Sanjay Punglia, CIT-DR

Section 143(3)Section 263Section 68

assessment proceedings, the A.O. raised specific queries with respect to the said 'Share Premium' charged on the shares allotted during the year including valuation of shares and in response, the detailed submission was furnished before the ld. A.O. by clearly justifying valuation of shares at Rs.25.86 per share against issue

DIABETOMICS MEDICAL PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, all the three appeals of the Assessee\nare partly allowed

ITA 2149/HYD/2025[2018-19]Status: DisposedITAT Hyderabad11 Feb 2026AY 2018-19

For Appellant: \nCA MV Prasad AndFor Respondent: \nMS U Mini Chandran, CIT-DR

Section 56(2)(viib)

shares of the company. In\nview of the above we hold that the action of the AO by substituting\nthe method for the valuation of shares which was subsequently\nupheld by the learned CIT(A) is contrary to the provisions of law\nand therefore the same is not sustainable.”\n12.3

DIABETOMICS MEDICAL PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

ITA 2148/HYD/2025[2017-18]Status: DisposedITAT Hyderabad11 Feb 2026AY 2017-18

For Appellant: \nCA MV Prasad AndFor Respondent: \nMS U Mini Chandran, CIT-DR

Section 56(2)(viib)

DIABETOMICS MEDICAL PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

ITA 2147/HYD/2025[2016-17]Status: DisposedITAT Hyderabad11 Feb 2026AY 2016-17

For Appellant: CA MV Prasad AndFor Respondent: MS U Mini Chandran, CIT-DR

Section 56(2)(viib)

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 14(1)(2), MUMBAI vs. LIGHTHOUSE LEARNING PRIVATE LIMITED, MUMBAI

In the result, the appeal filed by the revenue stands dismissed

ITA 5433/MUM/2024[2020-21]Status: DisposedITAT Mumbai30 Jan 2026AY 2020-21

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 14ASection 250Section 32(1)Section 32(1)(ii)Section 43(1)Section 43(6)

always considered as an Intangible Asset and was eligible for depreciation u/s 32. 12. During the hearing, Ld. DR stressed upon the valuation of shares considered during amalgamation. But we noticed that Ld. CIT(A) at page 20 of its order had relied upon CBDT vide circular No.279/Misc. dated

K. G. FINVEST PRIVATE LIMITED,EAST DELHI vs. CENTRAL CIRCLE 29, DELHI, NEW DELHI

In the result, the appeal of the assessee is partly allowed

ITA 4330/DEL/2025[2015-16]Status: DisposedITAT Delhi29 Jan 2026AY 2015-16

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2015-16] K.G. Finvest Pvt. Ltd. Vs Central Circle-29, F-24 F/Floor, I.Sc Pankaj Delhi Central Market, Mandawali Fazalpur, Nr Natraj Vihar Society, I.P. Extn., New Delhi- 110092. Pan-Aaack4032H Appellant Respondent Appellant By Shri Sudesh Garg, Adv. & Shri Prince Bansal, Ca Respondent By Shri Jitender Singh, Cit Dr Date Of Hearing 26.11.2025 Date Of Pronouncement 29 .01.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 17.06.2025 Passed By Ld. Commissioner Of Income Tax (A)-30, New Delhi [“Ld. Cit(A)”] In Appeal No. Cit(A), Delhi-5/10256/2017-18 U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 29.12.2017 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2015-16. 2. Brief Facts Of The Case Are That Assessee Company Has Filed Its Return Of Income On 28.09.2015, Declaring Total Income Of Inr 5,09,130/-. The Case Was Selected Under Limited Scrutiny & Notice U/S 143(2) Followed By Statutory Notices Issued U/S 142(1) Were Issued From Time To Time. In Response, Assessee Filed Submissions & Relevant Details Alongwith Evidences. The Ao Observed That The Assessee Issued 8,40,000 Equity Shares Of Inr 10/- Each At A Premium Of Inr 490/- Each & The Valuation Of Shares Was Done By Following Dcf Method. However, The Ao Rejected The Method Of Valuation Of Share Adopted By The Assessee & Re-Computed The Value Per Share At Inr 50.35 Per Share As Per Nav Method & Made Addition Of Differential Amount Of Inr 37,77,06,000/- U/S 56(2)(Viib) Of The Act.

Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153CSection 250Section 56(2)Section 56(2)(viib)

observed that the assessee issued 8,40,000 equity shares of INR 10/- each at a premium of INR 490/- each and the valuation of shares was done by following DCF method. However, the AO rejected the method of valuation of share adopted by the assessee and re-computed ... equity shares at a total value of INR 500/- per share including premium of INR 490/- per share. Ld.AR submits that the valuation of shares is duly supported by the report of an independent valuer as authorized under the Act being a merchant banker who has submitted its report dated

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