“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

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

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

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

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

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

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

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

Max Hospitals and Allied Services Limited, Mumbai vs. Principal Commissioner of Income Tax Mumbai -3, Mumbai

In the result the appeal filed by the assessee stands dismissed

ITA 2907/MUM/2024[2018-19]Status: DisposedITAT Mumbai21 Nov 2024AY 2018-19

Bench: Smt. Beena Pillai & Smt Renu Jauhriassessment Year: 2018-19 Max Hospitals & Principal Allied Services Commissioner Of 401, 4Th Floor, Income Tax Mumbai- 3 Man Excellenza, Room No.612, Vs. S. V. Road, 6Th Floor, Vile Parle (W.), Aayakar Bhavan, Mumbai- 400056 Maharishi Karve Road, Pan: Aagcr9198D Mumbai- 400020. Appellant : Respondent

For Appellant: RespondentFor Respondent: Ms. Sanyogia Nagpal (CIT-DR)

Section 143(3)Section 14ASection 263Section 56(2)(viib)

learned Assessing Officer has accepted the valuation & allowed the same after making proper & specific enquiry with reference to Section 56(2)(viib) for valuation of shares. The assessment order was passed by the Assessing Officer after due application of mind and after making due investigation / enquiries, which fact is clearly ... assessee Company has also submitted copies of valuation reports of shares issued by category 1 Merchant Banker Spa Capital Advisors Limited certifying the valuation of shares of the Company on the relevant dates. The learned Assessing Officer has verified all these details submitted to him during the course of assessment

Sills Karingattil Jose, Nedumkandom vs. ITO Ward 2, Thodupuzha

Appeal is partly allowed for statistical purpose

ITA 132/COCH/2023[2016-17]Status: DisposedITAT Cochin19 Nov 2024AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singhsils Karingattil Jose Income Tax Officer Np 3/406, Karingattil Ward - 2, House, Munnar Road Thodupuzha Vs. Nedumkandom P.O. [Pan: Afopj8789C] (Appellant) (Respondent)

For Appellant: Shri P. M. Veeramani, CAFor Respondent: Smt. V. Swarnalatha, Sr. D.R

Section 2(47)Section 2(47)(V)Section 250Section 50CSection 53ASection 56(2)(vii)

difference of Rs. 11,67,900/- as escapement of income. 5.2 During the assessment proceedings, the appellant argued that the valuation of shares has been done through 4 Sils Karingattil Jose DCF method. The appellant also submitted the valuation report. The Assessing Officer found that it is not backed ... appellant in the appellate proceedings has submitted that the revenue authorities cannot force the appellant to adopt particular method to valuation of shares. Reliance has been placed upon certain decisions of Hon’ble Tribunal. I have gone through the decisions cited by the appellant. They are not applicable

Assistant Commissioner of Income-Tax, Corporate Circle 1(1), Chennai vs. Amar Prakash Developers Private Limited, Chrompet, Chennai

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

ITA 577/CHNY/2024[2017-18]Status: DisposedITAT Chennai14 Nov 2024AY 2017-18

Bench: Shri Manu Kumar Giri & Shri Amitabh Shuklaआयकर अपील सं./Ita No.577/Chny/2024 धििाारण वर्ा /Assessment Year: 2017-18 Asst. Commissioner Of Income Amar Prakash Developers Tax, Corporate Circle-1(1), Vs. Pvt. Ltd, Chennai No.314, Pattamal Complex, G.S.T.Road, Chrompet, Tamil Nadu-600 044. [Pan: Aahca6244J]

For Respondent: Shri V.Nandakumar, CIT

Section 250Section 56(2)(viib)

regarding the an addition of Rs.96,41,47, 142/- made by the Ld. AO on account of variations made in the valuation of shares adopted by the assesse and those determined by the Ld. AO. The Ld. DR submitted that during the year the assesse has entered into a business ... scheme of valuation provided in the rule. It is the case of the department that in view of the :- 3 -: disclaimer’s the valuation of shares based on discounted cash flow method (DCF) suffered from defects to be accepted as a credible document for the valuation. The Ld. Counsel

ACIT, Central Circle-1, Noida vs. Amarpreet Anand, Chandigarh

ITA 1040/DEL/2022[2010-11]Status: DisposedITAT Delhi12 Nov 2024AY 2010-11

Bench: Shri Pradip Kumar Kedia & Shri Sudhir Kumaracit, Vs. Amarpreet Anand Central Circle-1, 1155, Sector-34C, Chandigarh, Income Tax Office, 2Nd Floor, Arto Complex, Sector-33, Noida, Pan No.Abzpa4892Q Uttar Pradesh. (Appellant) (Respondent) & Cross Objection No.63/Del/2023 (In Ita No.1040/Del/2022) (Assessment Year: 2010-2011) Amarpreet Anand Vs. Acit, 1155, Sector-34C, Central Circle-1, Chandigarh, Income Tax Office, 2Nd Floor, Arto Complex, Sector-33, Noida, Pan No.Abzpa4892Q Uttar Pradesh. (Appellant) (Respondent) Assessee By Shri Akhilesh Kumar, Adv. & Shri Vipin Garg, Adv. Revenue By Ms. Sapna Bhatia, Cit Dr Date Of Hearing: 25.09.2024 Date Of Pronouncement: 12.11.2024 O R D E R Per Pradip Kumar Kedia, Am:

shares of the company, whereas another shareholder Ashish Anand held 4,75,300 shares. The Ld. Counsel also pointed out that the valuation of shares as per Rule 11UA ITA No.1040/Del/2022 & CO No.63/Del/2023 Amarpreet Anand 10 of the Rules (although not applicable in the said year) as on 31.03.2009 would

People Care Hospitals Private Limited, Faridabad vs. ITO, Ward 2(1), Faridabad

In the result, the appeals of the assesses are allowed

ITA 100/DEL/2021[2016-17]Status: DisposedITAT Delhi08 Nov 2024AY 2016-17

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2016-17 People Care Hospitals Private Vs Ito Limited, Plot No.1066, Baba Ward- 2 (1) Nagar, Near Janta Barat Ghar, Faridabad Old Faridabad, Haryana 121002 Pan No.Aagcp8745G (Appellant) (Respondent) Assessment Year: 2016-17 Geranium Barkers Pvt. Ltd. Vs Ito 103/B, Near Shyamji Mandir Ward-1 (3) Malerna Road, Adarsh Nagar, Faridabad Ballabgarh Haryana -122004 Pan No.Aafcg3396P (Appellant) (Respondent) Assessment Year: 2016-17 Riven Health Club Pvt. Ltd. Vs Ito Ff-9, Vishnu Place Near Ward- 2 (2) Neelam Flyover Sector-20B Faridabad Faridabad Haryana121001 Pan No. Aagcr1343A (Appellant) (Respondent) Appellants By Sh. Rajeev Saxena, Advocate Ms. Sumangla Saxena, Advocate Sh. Dishant Sethi, Advocate

Section 131oSection 142(1)Section 143Section 143(2)Section 143(3)Section 251(1)Section 271(1)(c)Section 56(2)(viib)Section 68

fair market value of the share is required to be determined either by the Merchant Banker or by the Chartered Accountant. The valuation of shares based on DCF is basically to see the future year's revenue and profits projected and then discount the same to arrive at the present ... accepted the DCF methoc adopted by the assessee and he analyzed the factual performance of the assessee subsequent to issue o: shares. The valuation of shares are for that matter any valuation is itself is a projection of future events oi activities and no doubt it has to be done

Gujarat Farm Seeds Pvt. Ltd., Anand vs. The ITO, Ward-2, Anand

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

ITA 431/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad06 Nov 2024AY 2014-15

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. No. 431/Ahd/2024 ("नधा"रण वष" / Assessment Year:2014-15)

For Appellant: Vora, A.RsFor Respondent: Date of Hearing

Section 143(3)Section 250Section 56(2)(viib)Section 56(2)(vilib)

Asset Value (‘NAV’) method or as per DCF method and that the Revenue cannot force the assessee to adopt anyone particular method of valuation of shares. Therefore, the rejection of DCF method as adopted by the assessee was not correct. The Ld. AR further submitted that assessee had given ... vs.ITO] A.Y. 2014-15 -5 – rejecting the DCF method of valuation of the assessee, the AO had adopted NAV method for the valuation of shares. 8. The action of the AO in rejecting the DCF method and thereafter suo-moto adopting NAV method for determining fair market value of shares

Clonz Biotech Private Limited, Hyderabad vs. ITO., Ward-1(4), Hyderabad

In the result, the appeal of the assessee is dismissed

ITA 636/HYD/2024[2017-18]Status: DisposedITAT Hyderabad06 Nov 2024AY 2017-18

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdiaassessment Year: 2017-18 Clonz Biotech Private Limited, Vs. The Income Tax Officer, Ward – 1(4), Hyderabad. Hyderabad. Pan : Aadcc7742B. (Appellant) (Respondent) Assessee By: None Revenue By: Shri Srikanth Reddy, Y. Sr.Ar Date Of Hearing: 06.11.2024 Date Of Pronouncement: 06.11.2024

For Appellant: NoneFor Respondent: Shri Srikanth Reddy, Y. Sr.AR

Section 142(1)Section 143(2)Section 143(3)Section 56(2)(vii)Section 56(2)(viib)Section 68

merchant bankers, provided the valuation. Due to the lack of adequate proof regarding the creditworthiness of the shareholders and the discrepancy in share valuation, the share premium amounting to Rs.4,72,78,397/-, along with the share capital of Rs. 87,19,700/-totaling ... other hand, ld.DR submitted that the assessee has relied on the report furnished by the statutory auditor for the purpose of valuation of shares. Ld.DR further submitted that the statutory auditor was appointed by the assessee and therefore, there was disability for the statutory auditor to be appointed

Assistant Commissioner of Income Tax, Nungambakkam vs. R K M Powergen Private Limited, T Nagar

In the result the appeal of the revenue for the both the

ITA 800/CHNY/2023[2013-14]Status: DisposedITAT Chennai06 Nov 2024AY 2013-14

Bench: Shri Mahavir Singh, Hon’Ble & Shri S. R. Raghunatha, Hon’Ble

For Appellant: Shri. A. Sasikumar, CITFor Respondent: Shri. V. Ravichandran, CA

Section 56(1)

share. There is circuit fund flow. 7.5.6 The Appellant submitted that the share prices are determined by commercial negotiations with investors. The valuation of shares based on the Discounted Cash Flow (DCF) method (for AY 2010-11, it is as per CCI guidelines) was done only to comply with

Assistant Commissioner of Income Tax, Chennai vs. R K M Powergen Pvt. Ltd., Chennai

In the result the appeal of the revenue for the both the

ITA 799/CHNY/2023[2014-15]Status: DisposedITAT Chennai06 Nov 2024AY 2014-15

Bench: Shri Mahavir Singh, Hon’Ble & Shri S. R. Raghunatha, Hon’Ble

For Appellant: Shri. A. Sasikumar, CITFor Respondent: Shri. V. Ravichandran, CA

Section 56(1)

Riven Health Club Pvt. Ltd., Faridabad vs. ITO Ward-2(2), Faridabad

In the result, the appeals of the assesses are allowed

ITA 103/DEL/2021[2016-17]Status: DisposedITAT Delhi06 Nov 2024AY 2016-17

Section 131oSection 142(1)Section 143Section 143(2)Section 143(3)Section 251(1)Section 271(1)(c)Section 56(2)(viib)Section 68

Geranium Bakers Private Lmited, Ballabhgarh vs. ITO Ward-1(3), Faridabad

In the result, the appeals of the assesses are allowed

ITA 102/DEL/2021[2016-17]Status: DisposedITAT Delhi06 Nov 2024AY 2016-17

Section 131oSection 142(1)Section 143Section 143(2)Section 143(3)Section 251(1)Section 271(1)(c)Section 56(2)(viib)Section 68

Fly With Vip Online Private Limited, Sewri Mumbai vs. Dy. Commissioner of Income Tax - 5(1)(2), Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 4656/MUM/2024[2013-14]Status: DisposedITAT Mumbai29 Oct 2024AY 2013-14

Bench: Shri. B.R. Baskaran & Shri. Anikesh Banerjee

For Appellant: Shri Ravikant PathakFor Respondent: Shri Ashish Kumar (SR.AR.)

Section 143(3)Section 250Section 56(2)Section 56(2)(vib)Section 56(2)(viib)

call in advance from authorized shareholders towards issue of equity shares and the same are duly accounted in the books of account. The valuation of shares was based on the valuation report for both the share prices Rs.414/- per share and Rs.715/- per share. Such valuation was arrived

Parexel International Services India Pvt.Ltd, Chandigarh vs. ACIT, Circle-5(1), (Neac), Chandigarh

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

ITA 129/CHANDI/2021[2016-17]Status: DisposedITAT Chandigarh28 Oct 2024AY 2016-17

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Dhanesh Bafna, CAFor Respondent: Shri Reuben Mathew Jacob, Addl. CIT, Sr. DR

Section 143(3)Section 234BSection 271(1)(C)

same or similar uncontrolled transaction with or between non associated enterprises, under similar circumstances, considering all the relevant facts, for example, a valuation of shares obtained from an independent expert determining the value / price of shares that would have been charged in case of purchase / sale of such shares

Assistant Commissioner of Income Tax, Indore vs. Commander Industries Private Limited, Indore

ITA 24/IND/2024[2020-21]Status: DisposedITAT Indore25 Oct 2024AY 2020-21

Section 139(1)Section 142(1)Section 143(2)Section 32(1)Section 43(1)Section 43(6)(c)Section 47

appellant has furnished copy of Hon'ble NCLT Order dated 20.07.2020, Working of goodwill arising on merger, copy of valuation report for valuation of shares and share exchange ratio of the Registered Valuer, copy of the composite scheme of merger and amalgamation amongst four companies and the appellant company & statement

Dhola Infra Projects Limited (Formerly Known As Navayuga Dhola Infra Projects Limited), Mumbai vs. ACIT., Circle-16(1), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 800/HYD/2024[2016-17]Status: DisposedITAT Hyderabad17 Oct 2024AY 2016-17

Bench: Shri Laliet Kumar, Hon’Bleassessment Year – 2016-17 Dhola Infra Projects Limited Vs. Asst.Commissioner Of Tax (Formerly Known As Navayuga Circle-16(1) Dhola Infra Projects Limited Hyderabad Mumbai Pan : Aadcn3696B (Appellant) (Respondent) Assessee By: Shri Paras S.Savla, Ld.Ar (Through Virtual Hearing) Revenue By: Shri U Mini Chandran, Ld.Dr Date Of Hearing: 17.10.2024 Date Of Pronouncement: 17.10.2024

For Appellant: Shri Paras S.Savla, Ld.ARFor Respondent: Shri U Mini Chandran, Ld.DR

Section 234DSection 244ASection 56(2)(viib)

circumstances of the case and in law, the learned CIT(A) erred in upholding the action of the Assessing Officer in rejecting the valuation of shares determined by an independent account using Discounted Cash Flows Method (“DCF Method”) which is in accordance with Section 56(2)(viib ... method. The Ld.AR had drawn our attention to valuation report at Page No.52 of the paper book, on the basis of which, NAV valuation per share was calculated at Rs.300.61/- rounded to Rs.300/-. Further, the table shows details of shareholders to whom shares were allotted at Page No.52

Ace Cabs Limited, Delhi vs. ACIT, Circle-1(2), Delhi, C R Building

In the result, appeal filed by the assessee is allowed

ITA 443/DEL/2024[2017-18]Status: DisposedITAT Delhi04 Oct 2024AY 2017-18

Bench: Shri Saktijit Dey, Hon’Ble & Shri S.Rifaur Rahmanace Cabs Limited, Vs. Acit, Circle 1 (2), 562, Silver Oak Lane, Delhi. M.G. Road, Ghitorni, Delhi – 110 030. (Pan : Aaica4494R) (Appellant) (Respondent) Assessee By : Shri Gaurav Jain, Advocate Ms. Bharti Sharma, Advocate Revenue By : Shri Kanv Bali, Sr. Dr Date Of Hearing : 23.07.2024 Date Of Order : 04.10.2024 Order Per S.Rifaur Rahman,Am: 1. This Appeal Has Been Filed By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals), New Delhi [“Ld. Cit(A)”, For Short]/ National Faceless Appeal Centre (Nfac) Dated 12.12.2023 For The Assessment Year 2017-18. 2. The Assessee Submitted An Application Under Rule 29 Of The Itat Rules For Admitting The Additional Evidences & The Contents Thereof Are Reproduced Below:-

For Appellant: Shri Gaurav Jain, AdvocateFor Respondent: Shri Kanv Bali, Sr. DR

Section 142(1)Section 143(2)

scrutiny to examine the issue of large share premium, the AO, during the entire assessment proceedings, primarily focused on the justification of high valuation of shares done by the assessee, correctness of DCF method adopted for the valuation, and the applicability of the provisions of Section 56(2)(viib ... adopted by the assessee, asking it to explain why, based on certain irregularities allegedly identified by the AO in the valuation report, the valuation of shares using the DCF method should not be rejected, and the NAV method should be utilized instead. (vii) The assessee filed its reply

Balhanuman Commodeal Pvt. Ltd., Kolkata vs. ITO, Ward-5(4), Kolkata

ITA 116/KOL/2024[2012-13]Status: DisposedITAT Kolkata03 Oct 2024AY 2012-13

Bench: Shri Sanjay Garg & Shri Rakesh Mishraassessment Year: 2012-13

For Appellant: NoneFor Respondent: Shri Vineet Kumar, Addl. CIT, Sr. DR

Section 131Section 143(2)Section 143(3)Section 14ASection 250Section 68

company because every investor wants to earn income from investment in the form of dividend as well as expects appreciation in the valuation of shares with the growth of business. If this has been the situation, then there would have been no doubt on the genuineness of the transactions

Go Fashion (India) Limited, Nungambakkam, Chennai vs. PCIT, Chennai-1, Nungambakkam Chennai

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

ITA 939/CHNY/2024[2018-19]Status: DisposedITAT Chennai27 Sept 2024AY 2018-19

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.939/Chny/2024 िनधा9रण वष9 /Assessment Year: 2018-19 Go Fashion (India) Ltd., The Principal Commissioner Of 4 (Old 144), Sathak Center, Vs. Income Tax, Fifth Floor, Chennai-1. Nungambakkam High Road, Nungambakkam S.O, Nungabakkam, Chennai-600034. [Pan: Aadcg 9557C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Shri S. Ramachandran, Fca Hiथ" की ओर से /Respondent By Shri R. Clement Ramesh Kumar, Cit : सुनवाई की तारीख/Date Of Hearing : 10.07.2024 घोषणा की तारीख /Date Of Pronouncement : 30.09.2024 आदेश / O R D E R Per Jagadish, A.M : Aforesaid Appeal Filed By The Assessee For Assessment Year (Ay) 2018-19 Arises Out Of The Order Of Learned Principal Commissioner Of Income Tax, Chennai-1 [Hereinafter “Pcit”] Dated 29.02.2024 Passed U/S. 263 Of The Income-Tax Act, 1961 (Hereinafter “The Act”). :- 2 -:

For Appellant: Shri S. Ramachandran, FCA

Section 142(1)Section 143(3)Section 263Section 56(2)Section 56(2)(viib)

Authorized Representative (A.R) of the assessee has submitted that the A.O during assessment proceedings has called for particulars including the valuation of shares under Rule 11UA in the notice u/s. 142(1) of the Act. The Ld. AR has submitted that the A.O has specifically raised question on the issue

M/S Raj Kumar Singh & Co., Lucknow vs. Dy. Commissioner of Income Tax, Lucknow

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

ITA 1288/LKW/1993[1990-91]Status: DisposedITAT Lucknow26 Sept 2024AY 1990-91

Bench: Shri Sudhanshu Srivastava & Shri Anadee Nath Misshra

I.T.A. No.1288/Lkw/1993 Assessment year:2090-91 1 IN THE INCOME TAX APPELLATE TRIBUNAL LUCKNOW BENCH ‘A’, LUCKNOW BEFORE SHRI SUDHANSHU

DCIT, Central Circle-3(1), Hyderabad vs. Varsity Education Management Pvt Ltd, Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 208/HYD/2023[2011-12]Status: DisposedITAT Hyderabad20 Sept 2024AY 2011-12

Bench: Shri Manjunatha, G. & Shri Prakash Chand Yadavआ.अपी.सं /Ita No. 208/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2011-12) Deputy Commissioner Of Vs. Varsity Education Income Tax, Central Circle Management (P) Ltd 3(1) Hyderabad Hyderabad Pan:Aadcv6100E (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate A.V. Raghuram राज" व "ारा/Revenue By:: Shri B. Balakrishna, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 18/09/2024 घोषणा की तारीख/Pronouncement: 20/09/2024 आदेश/Order

For Appellant: Advocate A.V. RaghuramFor Respondent: : Shri B. Balakrishna, CIT(DR)

Section 271(1)(c)Section 274Section 68

resident venture capital company and the transaction is duly reported and there is only a difference in the perspective of the valuation of shares, which is evident from the findings of the Assessing Officer in the assessment order where, the Assessing Officer never disputed the identity and genuineness