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“valuation of shares”

Special Rate ProvisionsRule 11UARule 11UA508 judgments

The decision most relied on for valuation of shares is PCIT v. Chain House International (P) Ltd. (98 Taxmann.com 47), cited in 104 judgments on BharatTax.

Leading authorities on valuation of shares

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. George Henderson & Co. Ltd.
66 ITR 622 · 1967 · Supreme Court
82
citing judgments

The 'full value of consideration' for computing capital gains under Section 48 of the Income Tax Act, 1961 (or its predecessor, Section 12B of the 1922 Act), means the actual price bargained for and received or accrued by the parties. It does not refer to the market value or any notional value of the asset transferred.

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.

CIT v. Green Infra Ltd.
78 Taxmann.com 340 · 2017 · High Court
56
citing judgments

The valuation of shares is not relevant for determining the genuineness of a transaction under Section 68 of the Income Tax Act. Interest income earned on the deposit of surplus funds is taxable as business income.

CIT v. Bank of Baroda
262 ITR 334 · 2003 · High Court
51
citing judgments

An assessee is entitled to claim a deduction for the depreciation in the value of investments, such as shares and securities, if these investments are valued at cost or market value, whichever is lower, consistent with the real income principle.

PCIT v. Cinestaan Entertainment Pvt Ltd.
433 ITR 82 · 2021 · High Court
49
citing judgments

The Assessing Officer cannot reject the share valuation method adopted by an assessee under Section 56(2)(viib) if it adheres to prescribed methodologies and commercial prudence. The valuation cannot be challenged based on future performance or by substituting another method.

Jeevan Investment & Finance (P.) Ltd. v. CIT
88 Taxmann.com 552 · 2017 · High Court
37
citing judgments

An Assessing Officer's failure to conduct necessary inquiries renders the assessment order erroneous and prejudicial to the revenue, justifying revision under Section 263.

Innoviti Payment Solutions Pvt. Ltd. v. ITO
102 Taxmann.com 59 · 2019 · ITAT
35
citing judgments

The Assessing Officer (AO) cannot discard the Discounted Cash Flow (DCF) method for share valuation if the assessee opts for it as per Rule 11UA(2). The AO must record reasons for not accepting the assessee's valuation report and obtain a fresh report before proceeding with their own valuation, but cannot change the method chosen by the assessee.

Judgments citing valuation of shares

Abc Sales Corporation, Kannur vs. ACIT, Central Circle-1, Kozhikode

In the result, appeal of the assessee is hereby dismissed

ITA 440/COCH/2024[2017-2018]Status: DisposedITAT Cochin20 Dec 2024AY 2017-2018

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

From these observations, we find merit in the assessee's contention that the investor agreement and the Excel sheet, which purportedly detailed the valuation of shares in the three existing companies, were projections and never materialized. The revenue has not provided any additional evidence beyond the Excel sheets to prove

Abc Sales Corporation, Kasaragod vs. ACIT, Central Circle-1, Kozhikode

In the result, appeal of the assessee is hereby dismissed

ITA 439/COCH/2024[2017-2018]Status: DisposedITAT Cochin20 Dec 2024AY 2017-2018

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

From these observations, we find merit in the assessee's contention that the investor agreement and the Excel sheet, which purportedly detailed the valuation of shares in the three existing companies, were projections and never materialized. The revenue has not provided any additional evidence beyond the Excel sheets to prove

Bathx Bathware India Private Limited, Cochin vs. ACIT, Central Circle-1, Kozhikode

In the result, appeal of the assessee is hereby dismissed

ITA 438/COCH/2024[2016-2017]Status: DisposedITAT Cochin20 Dec 2024AY 2016-2017

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

From these observations, we find merit in the assessee's contention that the investor agreement and the Excel sheet, which purportedly detailed the valuation of shares in the three existing companies, were projections and never materialized. The revenue has not provided any additional evidence beyond the Excel sheets to prove

Bathx Bathware India Private Limited, Kochin vs. ACIT, Central Ircle-1, Kozhikode

In the result, appeal of the assessee is hereby dismissed

ITA 437/COCH/2024[2015-2016]Status: DisposedITAT Cochin20 Dec 2024AY 2015-2016

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

From these observations, we find merit in the assessee's contention that the investor agreement and the Excel sheet, which purportedly detailed the valuation of shares in the three existing companies, were projections and never materialized. The revenue has not provided any additional evidence beyond the Excel sheets to prove

Bathx Bathware India Private Limited, Kochin vs. ACIT, Central Circle-1, Kozhikode

In the result, appeal of the assessee is hereby dismissed

ITA 436/COCH/2024[2014-2015]Status: DisposedITAT Cochin20 Dec 2024AY 2014-2015

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

From these observations, we find merit in the assessee's contention that the investor agreement and the Excel sheet, which purportedly detailed the valuation of shares in the three existing companies, were projections and never materialized. The revenue has not provided any additional evidence beyond the Excel sheets to prove

A B C Sales Corporation, Kannur vs. ITO, Circle-1, Kannur

In the result, appeal of the assessee is hereby dismissed

ITA 404/COCH/2024[2017-2018]Status: DisposedITAT Cochin20 Dec 2024AY 2017-2018

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

From these observations, we find merit in the assessee's contention that the investor agreement and the Excel sheet, which purportedly detailed the valuation of shares in the three existing companies, were projections and never materialized. The revenue has not provided any additional evidence beyond the Excel sheets to prove

Abc Buildware India (P) Limited, Kannur vs. ITO, Circle-1, Kannur

In the result, appeal of the assessee is hereby dismissed

ITA 389/COCH/2024[2017-2018]Status: DisposedITAT Cochin20 Dec 2024AY 2017-2018

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

From these observations, we find merit in the assessee's contention that the investor agreement and the Excel sheet, which purportedly detailed the valuation of shares in the three existing companies, were projections and never materialized. The revenue has not provided any additional evidence beyond the Excel sheets to prove

Autope Payment Solutions Private Limited, Ghaziabad vs. ACIT, Circle-2(2), Delhi

In the result, ground nos

ITA 86/DEL/2023[2017-18]Status: DisposedITAT Delhi20 Dec 2024AY 2017-18

Bench: Shri Mahavir Singh & Shri S. Rifaur Rahmanassessment Year : 2017-18

For Appellant: Shri Akhilesh Kumar, Adv.; &For Respondent: Shri Yogesh Kumar Nayyar, Sr. DR
Section 142(1)Section 143(2)Section 143(3)Section 56(2)

left to the consideration and wisdom of experts in the field of accountancy, having regard to the imponderables which enter the process of valuation of shares. The Appellant-Revenue is unable to demonstrate that the methodology adopted by the Respondent-Assessee is not correct. The AO has simply rejected ... same share which are issued by the assessee with share premium. We have already held in ground no. 3 that valuations of shares are proper based on the DCF method. Further, we observe that the shares were issued to the existing shareholders, therefore, the Assessing Officer cannot invoke the provisions

Shaha Finlease Private Limited, Mumbai vs. Dy Commissioner of Income Tax 13(2)(2), Mumbai

In the result, appeal of the assessee is allowed

ITA 4182/MUM/2023[2013-14]Status: DisposedITAT Mumbai17 Dec 2024AY 2013-14

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

Section 143(3)Section 56Section 56(1)(viib)Section 68

being addition of securities premium under section 56 (2) (vii)(b) without appreciating the fact that the Id. AO cannot disregard valuation of shares and substitute own method without pointing out any defects in the same. 4. Ld. CIT(A) erred in law as well as on fact in confirming ... assessee. Also, no person would give debt to such a company (loss-making company) @ 8% i.e., the rate of interest considered for valuation of shares. This is especially important in view of the fact that the company was having negative net worth with accumulated losses of Rs.6

The ACIT, Circle-2(1)(1), Ahmedabad vs. Mayora India Private Limited (Formerly Known As, Ahmedabad

In the result, the appeals of the Department are dismissed

ITA 419/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad16 Dec 2024AY 2018-19

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Tushar Hemani, Sr. Adv. & ShriFor Respondent: Shri R. N. Dsouza, CIT D.R
Section 68

liable to be added as income/of the company, if the amount is received from a nonresident. In the present case even if the valuation of shares is not reliable, no addition can be made as the amounts are received from NRI. Considering the above, the addition made

The ACIT, Circle-2(1)(1), Ahmedabad vs. Mayora India Private Limited (Formerly Known As "Inbisco India Pvt. Ltd.), Ahmedabad

In the result, the appeals of the Department are dismissed

ITA 418/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad16 Dec 2024AY 2017-18

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Tushar Hemani, Sr. Adv. & ShriFor Respondent: Shri R. N. Dsouza, CIT D.R
Section 68

liable to be added as income/of the company, if the amount is received from a nonresident. In the present case even if the valuation of shares is not reliable, no addition can be made as the amounts are received from NRI. Considering the above, the addition made

Mili Marketing Pvt Ltd., New Delhi vs. ITO, Ward-16(4), New Delhi

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

ITA 2319/DEL/2023[2016-17]Status: DisposedITAT Delhi12 Dec 2024AY 2016-17

Bench: Shri Pradip Kumar Kedia & Shri Yogesh Kumar Us[Assessment Year : 2016-17] M/S. Mili Marketing Pvt.Ltd., Vs Ito, H-108, Connaught Circus, Ward-16(4), New Delhi-110001. New Delhi. Pan-Aabcm7097H Appellant Respondent Appellant By Shri Ved Jain, Adv & Shri Aman Garg, Ca Respondent By Ms. Smita Singh, Sr.Dr Date Of Hearing 12.09.2024 Date Of Pronouncement 12.12.2024

Section 133(6)Section 143(3)Section 68

advances", on the asset side has been shown as 10,55,56,960/- as on 31.03.2015 for the purpose of arriving at the valuation of share at Rs.268/-. Surprisingly, this figure gets reduced to merely Rs. 1,95,74,964/- as on 31.03.2016. It is not clear as to where ... these assets, which were the main foundation for valuation of shares, got vanished from the balance sheet of the assessee in the immediate succeeding financial year. Clearly the basis for premium valuation suffers from severe infirmities and hence, is incorrect and fallacious. 8.7 The explanation for the share premium

Indus Towers Limited (Formerly Known As Bharti Infratel Ltd and As Successor in Interest of Erstwhile Indus Tower Ltd), Gurugram, Haryana vs. DCIT, Circle 12(1), New Delhi

In the result, the appeal of the revenue is dismissed

ITA 2762/DEL/2023[2010-11]Status: DisposedITAT Delhi10 Dec 2024AY 2010-11

Bench: Shri M. Balaganesh & Shri Vimal Kumarindus Towers Ltd (Formerly Vs. Dcit, Known As Bharti Infratel Ltd), Circle-12(1), 4Th Floor, Dlf Cybercity, New Delhi Building No. 10, Tower A, Dlf Qe, So Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Acit, Vs. Indus Towers Ltd, 4Th Floor, Dlf Cybercity, Central Circle-10, New Delhi Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Indus Towers Ltd (Formerly Vs. Dcit, Known As Bharti Infratel Ltd), Circle-12(1), 4Th Floor, Dlf Cybercity, New Delhi Building No. 10, Tower A, Dlf Qe, So Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Assessee By : Shri Ajay Vohra, Sr. Adv Shri Rohit Jain, Adv Shri Deepesh Jain, Adv Ms. Shaurya Jain, Ca Revenue By: Shri Mukesh Kumar Jain, Cit Dr Date Of Hearing 12/09/2024 Date Of Pronouncement 10/12/2024

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Mukesh Kumar Jain, CIT DR
Section 115JSection 139(5)Section 142Section 143(3)Section 148

INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “C”: NEW DELHI BEFORE SHRI M. BALAGANESH, ACCOUNTANT MEMBER AND SHRI VIMAL KUMAR, JUDICIAL

ACIT, Circle 10, New Delhi vs. Indus Tower Limited, Gurgaon

In the result, the appeal of the revenue is dismissed

ITA 2212/DEL/2023[2010-11]Status: DisposedITAT Delhi10 Dec 2024AY 2010-11

Bench: Shri M. Balaganesh & Shri Vimal Kumarindus Towers Ltd (Formerly Vs. Dcit, Known As Bharti Infratel Ltd), Circle-12(1), 4Th Floor, Dlf Cybercity, New Delhi Building No. 10, Tower A, Dlf Qe, So Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Acit, Vs. Indus Towers Ltd, 4Th Floor, Dlf Cybercity, Central Circle-10, New Delhi Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Indus Towers Ltd (Formerly Vs. Dcit, Known As Bharti Infratel Ltd), Circle-12(1), 4Th Floor, Dlf Cybercity, New Delhi Building No. 10, Tower A, Dlf Qe, So Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Assessee By : Shri Ajay Vohra, Sr. Adv Shri Rohit Jain, Adv Shri Deepesh Jain, Adv Ms. Shaurya Jain, Ca Revenue By: Shri Mukesh Kumar Jain, Cit Dr Date Of Hearing 12/09/2024 Date Of Pronouncement 10/12/2024

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Mukesh Kumar Jain, CIT DR
Section 115JSection 139(5)Section 142Section 143(3)Section 148

INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “C”: NEW DELHI BEFORE SHRI M. BALAGANESH, ACCOUNTANT MEMBER AND SHRI VIMAL KUMAR, JUDICIAL

Indus Towers Ltd., Gurgaon vs. DCIT Circle 12(1), New Delhi

In the result, the appeal of the revenue is dismissed

ITA 1962/DEL/2023[2010-11]Status: DisposedITAT Delhi10 Dec 2024AY 2010-11

Bench: Shri M. Balaganesh & Shri Vimal Kumarindus Towers Ltd (Formerly Vs. Dcit, Known As Bharti Infratel Ltd), Circle-12(1), 4Th Floor, Dlf Cybercity, New Delhi Building No. 10, Tower A, Dlf Qe, So Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Acit, Vs. Indus Towers Ltd, 4Th Floor, Dlf Cybercity, Central Circle-10, New Delhi Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Indus Towers Ltd (Formerly Vs. Dcit, Known As Bharti Infratel Ltd), Circle-12(1), 4Th Floor, Dlf Cybercity, New Delhi Building No. 10, Tower A, Dlf Qe, So Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Assessee By : Shri Ajay Vohra, Sr. Adv Shri Rohit Jain, Adv Shri Deepesh Jain, Adv Ms. Shaurya Jain, Ca Revenue By: Shri Mukesh Kumar Jain, Cit Dr Date Of Hearing 12/09/2024 Date Of Pronouncement 10/12/2024

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Mukesh Kumar Jain, CIT DR
Section 115JSection 139(5)Section 142Section 143(3)Section 148

INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “C”: NEW DELHI BEFORE SHRI M. BALAGANESH, ACCOUNTANT MEMBER AND SHRI VIMAL KUMAR, JUDICIAL

ITO, Ward- 17(4), New Delhi vs. Navya Securities Pvt. Ltd., New Delhi

ITA 5565/DEL/2017[2013-14]Status: DisposedITAT Delhi09 Dec 2024AY 2013-14

Bench: Ms.Madhumita Roy & Smt. Renu Jauhriincome Tax Officer Vs. M/S Navya Securities Pvt. Ward-17(4) Ltd., B-2, Jangpura Room No. 225D, Extension, Cr Building, I.P. Estate New Delhi – 110014 New Delhi -2 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaacn3106H Appellant .. Respondent

For Appellant: Sh. Ruchesh Sinha, AdvFor Respondent: Sh. Amit Katosh, Sr. DR
Section 143(3)Section 71(2)

capital gain on sale of property with loss in investments made in shares during the year. Further that, there is no basis for valuation of share at high price of Rs.560 as has 3 ITO, Ward-17(4) Vs. M/s Navya Securities Pvt. Ltd. been submitted by the assessee ... follows: a. The price of the shares was calculated as per the rule 11UA of the Income Tax Rules which pertains to the valuation of shares. The same has not been considered by the AO. b. At the time when the share was subscribed the said entity

Income Tax Officer, Main Building vs. Priya Estate Developers Private Limited, Abhiramapuram, Chennai

The appeal stand allowed for statistical purposes

ITA 1244/CHNY/2024[2016-17]Status: DisposedITAT Chennai03 Dec 2024AY 2016-17

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1244/Chny/2024 (िनधा*रण वष* / Assessment Year: 2016-17) Ito M/S. Priya Estate Developers Private Ltd. बनाम/ Corporate Ward-5(2) #11, Bashyam Basheer Ahmed Road Vs. Chennai. Alwarpet, Chennai-600 018. "थायीलेखासं./जीआइआरसं./Tan/Pan No. Aahcp-5405-G (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri R. Clement Ramesh Kumar (Cit) – Ld. Dr ""थ"कीओरसे/Respondent By : Shri R. Vijayaraghavan (Advocate) -Ld. Ar (Virtual) सुनवाईकीतारीख/Date Of Hearing : 24-09-2024 घोषणाकीतारीख /Date Of Pronouncement : 03-12-2024 आदेश / O R D E R

For Appellant: Shri R. Clement Ramesh Kumar (CIT) – Ld. DRFor Respondent: Shri R. Vijayaraghavan (Advocate) -Ld. AR
Section 143(3)Section 56(2)(viib)

shareholders which was required to be reduced from the total value of assets while determining the value per share. b. The valuation of share carried out by V. Suresh is erroneous considering that the said loan liability of Rs.37.23 Crores on the date of valuation was not reduced while determining ... value per share on the pretext that the same is of the nature of share capital advance/share application money, c. The valuation of shares dated 27.07.2020 carried out by M/s Integrated Enterprises (India) P. Ltd. using Discounted Cash Flow (DCF) method is erroneous considering that the assessee in the subsequent

Spl Infrastructure Pvt. Lt, Alwarpet, Chennai vs. ITO, Corporate Circle 6(1), Chennai

ITA 325/CHNY/2023[2018-19]Status: DisposedITAT Chennai29 Nov 2024AY 2018-19

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.325/Chny/2023 िनधा"रण वष"/Assessment Year: 2018-19 Spl Infrastructure Pvt. Ltd., Vs. The Income Tax Officer, 15, Kasturi Rangan Road, Corporate Circle – 6(1), Alwarpet, Chennai 600 018. Chennai. [Pan: Aaics0881N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.10.2024 घोषणा की तारीख /Date Of Pronouncement : 29.11.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 06.03.2023 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2018-19. 2. The Assessee Raised 11 Grounds Of Appeal. The Ld. Ar Shri N. Arjun Raj, Advocate, Drew Our Attention To Ground No. 11 & Submits That This Matter Requires To Be Remanded To The File Of The Assessing

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 56Section 56(2)(viib)

fresh consideration for not acting upon the valuation report issued by the Merchant Banker. He drew our attention to the report of valuation of shares issued by Sundae Capital Advisors Pvt. Ltd. at page 1 of the paper book and submits that the said report was furnished before the Assessing ... after the discussion with management of the appellant. During the assessment proceedings as well as appellate proceedings, the appellant had contended that the valuation of shares was determined on the market value of the land (immovable assets) whereas in the valuation report, this basis has not been considered and adopted

Ajit Kumar, Bokaro vs. ACIT, Circle 2(1), It, Kolkata

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

ITA 243/KOL/2024[2018-2019]Status: DisposedITAT Kolkata22 Nov 2024AY 2018-2019

Bench: Sri Rajesh Kumar & Pradip Kumar Choubey

Section 139Section 144CSection 144C(5)Section 147Section 148Section 148A

line with the market value of these shares as value of shares can easily be manipulated which results in over or under valuation of shares in the books of the beneficiary. As per the findings of the Investigation, you have taken bogus profit through scrips mentioned above, thereby taken benefit

Parasmani Gems Pvt. Ltd., Ahmedabad vs. The DCIT, Cir-3(1)(1), Ahmedabad

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

ITA 2263/AHD/2017[2013-14]Status: DisposedITAT Ahmedabad21 Nov 2024AY 2013-14

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. No. 2263/Ahd/2017 ("नधा"रण वष" / Assessment Year : 2013-14) बनाम/ Parasmani Gems Pvt. Ltd. The D.C.I.T. 2, Supan Complex, Nr. Circle 3(1)(1), Vs. Dharnidhar Derasar, Paldi, Ahmedabad Ahmedabad, Gujarat - 380006 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aadcp6337M (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Mehul K Patel, Ar ""यथ" क" ओर से/Respondent By : Shri Rignesh Das, Sr. Dr Date Of Hearing 23/10/2024 21/11/2024 Date Of Pronouncement

For Appellant: Shri Mehul K Patel, ARFor Respondent: Shri Rignesh Das, Sr. DR
Section 154Section 234ASection 56(2)(viib)

Tribunal and the CIT(Appeals) have held that the Assessing Officer had no jurisdiction to substitute the NAV method of assessing the valuation of shares, once the assessee had exercised option of a DCF valuation method as per Rule 11UA(2) of the Income Tax Rules. 20. We agree with ... issue of conversion of loan into share capital and the fact that the AO had no jurisdiction to substitute NAV method of valuation of shares when the assessee had opted DCF method of valuation. In the present case, however, the assessee has not explained as to why the first allotment