“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

Innovior Advisory Private Limited, Bangalore vs. Income Tax Officer, Ward-3(1)(3), Bangalore

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

ITA 1277/BANG/2024[2018-19]Status: DisposedITAT Bangalore18 Sept 2024AY 2018-19

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2018-19

For Appellant: Shri Deepak Chopra, CA

Section 143(3)Section 234BSection 56(2)Section 56(2)(viib)

above ground: 15,98,397/-) 4.1. The authorities below have erred in rejecting the discounted cash flow method adopted by the appellant for valuation of shares and have also erred in adopting Net Asset value method for computing the fair market value of the shares of the appellant. On proper

Venkateshwara Wires Pvt. Ltd., Jaipur vs. Assistant Commissioner of Income Tax, Jaipur

In the result, the appeal of the assessee is allowed

ITA 322/JPR/2024[2018-19]Status: DisposedITAT Jaipur09 Sept 2024AY 2018-19

Bench: The Ld. Ao As Well As Before The Ld. Cit(A) As The Documents Submitted Was Only In Support Of Confirmations & Other Documents Already Submitted & No New Documents Were Submitted. 2. The Assessee Craves Your Indulgence To Add Amend Or Alter All Or Any Grounds Of Appeal Before Or At The Time Of Hearing.”

For Appellant: Sh. S. L. Poddar, AdvFor Respondent: Sh. Anoop Singh, Addl. CIT

Section 133(6)Section 142(1)Section 143(3)Section 68Section 801ASection 80I

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

Apple Infra Build Pvt Ltd, Noida vs. ITO Ward - 3(1), New Delhi

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

ITA 9880/DEL/2019[2015-16]Status: DisposedITAT Delhi06 Sept 2024AY 2015-16

Bench: Shri Shamim Yahya & Ms. Madhumita Roym/S Apple Infra Build Pvt. Vs. Income Tax Officer, Ltd., Plot No. 24/32, Ward-3(1) Block-D, Sector- 63, New Delhi - 110075 Noida- 201301

For Appellant: NoneFor Respondent: Sh. Kanv Bali, Sr. D.R

Section 115JSection 143(3)Section 56(2)(viib)

equity shares of face value of Rs. 10 each issued till date of Valuation at 56.500 whereas actually on the date of valuation of shares shown as on 15.03.2015 the shares already issued are only 10,000 shares in number issued at face value @ Rs 10 per share The valuer ... Ward 3(1) “6.4.3 Considering the facts of the case, I am of the view that the AO has rightlyrejected the valuation of shares under DCF method In the case of Agro Portfolio (P)Ltd [2018] 94 taxmann.com 112 (Delhi Trib) Hon'ble ITAT Delhi has held that "Forall these

Leela Tourism and Heritage Private Limited, New Delhi vs. A0-ACIT, Circle 15(1), Delhi

In the result, the appeal of the assessee is allowed

ITA 3685/DEL/2023[2016-17]Status: DisposedITAT Delhi05 Sept 2024AY 2016-17

Bench: Shri Pradip Kumar Kedia & Shri Yogesh Kumar Usassessment Year 2016-17

For Respondent: Shri Subhra Jyoti Chakraborty, CIT-DR

Section 143(3)Section 234BSection 271(1)(C)Section 56(2)(viib)

11UA(1)(c)(b) of Income Tax Rules 1962 as per provisions of Section 56(2)(viib). The Assessing Office rejected 2 the valuation of shares of the assessee company after considering the fact that the property in subsidiary company was valued by the foreign valuer therefore assessee officer imposed ... valuation of share, which should not be a 'Fair Market Value'. Accordingly, added Rs.6,10,00,000- to the income of the assessee under Section 56(2)(viib) on the reasons recorded in Assessment Order, raising the following questions: 2. Whether method of valuation adopted by the assessee

Sparsh Beauty Care Pvt. Ltd., Haryana vs. ITO Ward-2(4), Haryana

In the result, the appeals of the assesses are allowed

ITA 86/DEL/2021[2016-17]Status: DisposedITAT Delhi05 Sept 2024AY 2016-17

Bench: Dr. B. R.R. Kumar & Sh. Sudhir Kumarassessment Year: 2016-17 M/S. Punyah Building Vs Ito Materials Pvt. Ltd. Ward-2 (1) House No.1002, Near Talab Faridabad Shiv Colony, Old Faridabad Haryana Ballahgarh Haryana 122002 Pan No.Aagcp8742B (Appellant) (Respondent) Assessment Year: 2016-17 Sparsh Beauty Care Pvt. Ltd. Vs Ito Plot No.1066, Near Janta Barat Ward-2 (4) Ghar Baba Nagar, Faridabad Faridabad Haryana 121002 Haryana Pan No.Aascs2575D (Appellant) (Respondent) Assessment Year: 2016-17 Speedy Courier Services Pvt. Vs Ito Ltd. Ward- 2 (4) Plot No.1022, Near Talab Shiv Faridabad Colony, Faridabad Haryana Pan No.Aascs2579R (Appellant) (Respondent)

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

under the head income from other sources by applying section 56(2)(viib) of the Act on protective basis and rejecting the valuation of shares as determined as per NAV method provided under Rule 11UA(2)(a) of Income Tax Rules, 1962. 3. That the Ld. CIT(A) has erred ... 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

Punyah Building Materials Pvt Ltd, Faridabad vs. ITO Ward - 2(1), Faridabad

In the result, the appeals of the assesses are allowed

ITA 81/DEL/2021[2016-17]Status: DisposedITAT Delhi05 Sept 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

Speedy Courier Services Pvt Ltd, Faridabad vs. ITO Ward - 2(4), Faridabad

In the result, the appeals of the assesses are allowed

ITA 80/DEL/2021[2016-17]Status: DisposedITAT Delhi05 Sept 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

Manidhari Oils Pvt Ltd, Ghaziabad vs. ITO Ward -17(1), New Delhi

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

ITA 4975/DEL/2019[2014-15]Status: DisposedITAT Delhi29 Aug 2024AY 2014-15

Bench: Sh. Pradip Kumar Kedia & Shri Yogesh Kumar U.S.I.T.A. No. 4975/Del/2019 (A.Y 2014-15)

For Appellant: Sh. C. S. Anand, Adv

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

PCIT Delhi-06 New Delhi that the AO had passed the assessment order, without taking into consideration the aspect of valuation of shares for the purposes of justification of charging of premium, is not correct. As a matter of fact, during the course of assessment proceedings ... taken into consideration the aspect of valuation of shares for the purposes of justification of charging of premium, and had passed the assessment order on being fully satisfied with the valuation report prepared by CA Deepak Kumar on 30.09.2013 (which was furnished by the assessee), through which the value

Vensun Laboratories Private Limited, Solapur vs. ACIT, Solapur

In the result, the appeal filed by the appellant company stands partly allowed for statistical purposes

ITA 655/PUN/2024[2015-2016]Status: DisposedITAT Pune21 Aug 2024AY 2015-2016

Bench: Shri Inturi Rama Rao & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.655/Pun/2024 "नधा"रण वष" / Assessment Year : 2015-16

For Respondent: Shri Ajay Kumar Keshari &

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

Authorised Representative for the appellant company submits that it is beyond the power of the Assessing Officer to substitute the method of valuation of shares adopted by the appellant company. He further submitted before the CIT(A)/NFAC that he had filed a detailed explanation furnishing the information called

Decent Industries P. Ltd., Bhopal vs. ITO-1(2), Bhopal

Appeal is partly allowed

ITA 356/IND/2023[2012-13]Status: DisposedITAT Indore20 Aug 2024AY 2012-13

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani(Virtual Hearing) Assessment Year: 2012-13 M/S Decent Industries Ito-1(2), Private Ltd, Bhopal 5Th Floor, Corporate Park, बनाम/ Db City Area Hills, Vs. Opp. M.P. Nagar Zone I, Bhopal (Assessee/Appellant) (Revenue/Respondent) Pan: Aaeca6271G Assessee By Ms. Shilpa Gupta & Shri N.K. Gupta Revenue By Shri V.K. Singh, Cit-Dr Date Of Hearing 04.06.2024 Date Of Pronouncement 20.08.2024

Section 133ASection 143(2)Section 147Section 148Section 14ASection 68

explain the justification of said security premium collected on issue of preference shares to above two companies and also to justify the valuation of shares with face value of Rs.10/- each at premium @ Rs. 990/-. No reply was received and therefore a show cause notice under section 144 was issued

Raghuleela Estates Private Limited, Bandra, Mumbai vs. PCIT (Central), Mumbai-3, Mumbai

In the result, appeal of the assessee is allowed

ITA 2594/MUM/2024[2020-21]Status: DisposedITAT Mumbai20 Aug 2024AY 2020-21

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Sandeep Singh Karhail, Hon’Ble

For Appellant: Shri Madhur Agarwal, A/RFor Respondent: Smt. Sanyogita Nagpal, CIT, D/R

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

Assessing Officer and remanded the matter back for a denovo consideration. The Assessing Officer had also not considered certain points regarding valuation of shares and payments for those shares. The assessee-respondent preferred an appeal before the ITAT against the order of remand of CIT and the ITAT had passed

Mim Components Bangalore Private Limited, Bangalore vs. Income-Tax Officer, Ward-4(1)(3), Bangalore

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

ITA 683/BANG/2024[2016-17]Status: DisposedITAT Bangalore08 Aug 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2016-17

For Appellant: Shri A. Ravish Rao, CAFor Respondent: Smt. S. Praveena, CIT-DR

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

increase in the turnover with the assessee might have subsequently earned. The assessee basically did not have any documents to support the valuation of shares at Rs.145 per share. It did not have any strong financials of its own in order to project a turnover that could justify its share ... would have no application. 4.5. In the above background, we deem it fit to provide another opportunity to the assessee to justify the valuation of shares in Page 15 of 15 terms of Sec.56(2)(viib). Accordingly, the matter stand restored back to the file of Ld.AO to provide another

Assistant Commissioner of Income Tax, Circle-1(1), New Delhi, C.R. Building vs. Addverb Technologies Pvt Ltd, New Delhi

In the result, the order of CIT(A) is upheld, and appeal of the Revenue is dismissed

ITA 3095/DEL/2023[2020-21]Status: DisposedITAT Delhi08 Aug 2024AY 2020-21

For Appellant: Ms. Neha Chaudhary, CIT-DRFor Respondent: Shri Ved Jain, Advocate, and Ms. Supriya Mehta, CA

Section 56(2)(viib)

assessee failed to show valid reasons for claiming excessive interest on repayment of loans. In so far as on the issue relating to valuation of shares she reiterated findings of the AO. 5. Per contra, Shri Ved Jain appearing on behalf of the assessee strongly supported the findings ... thereafter directed the AO to delete the addition. 5.1. With regard to addition u/s. 56(2)(viib) of the Act on account of valuation of shares, the ld. Counsel submitted that the assessee had issued 79852 shares with Face Value of Rs. 10/- per share at a premium

Smart Information Worldwide Inc, Chennai vs. ACIT International Taxation 2(2), Chennai

The appeal stand allowed in terms of our above order

ITA 330/CHNY/2024[2016-17]Status: DisposedITAT Chennai06 Aug 2024AY 2016-17

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.330/Chny/2024 (िनधा9रणवष9 / Assessment Year: 2016-17) M/S. Smart Information Worldwide Inc. Dcit बनाम/ 49 Sixth Main Road, International Taxation -2(2) Vs. Raja Annamalaipuram, Chennai-600 028. Chennai-6. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaocs-8497-G (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओरसे/ Appellant By : Shri V. Ravichandran (Ca)- Ld.Ar " थ"कीओरसे/Respondent By : Shri Ar.V.Sreenivasan (Addl.Cit)-Ld. Sr. Dr सुनवाई की तारीख/Date Of Hearing : 20-06-2024 घोषणा की तारीख /Date Of Pronouncement : 06-08-2024

For Appellant: Shri V. Ravichandran (CA)- Ld.ARFor Respondent: Shri AR.V.Sreenivasan (Addl.CIT)-Ld. Sr. DR

Section 143(3)Section 195Section 48Section 50CSection 50D

shares could not be determined and the provisions of Sec.50D gets attracted in the case of the assessee. Rule 11UA provide for valuation of shares under two methods namely Net Asst Method (NAV) and DCF Method. The values arrived by DCF method was Rs.2135 per shares whereas value ... share disregarding the agreement value between the assessee and Norwest. However, the aforesaid valuation, in our opinion, is clearly fallacious one since the valuation of shares would keep on fluctuating depending upon the performance of the underlying entity and the valuation could not be arrived merely on the basis

Smart Information Worldwide Inc, Chennai vs. DCIT International Taxation 2(2), Chennai

The appeal stand allowed in terms of our above order

ITA 329/CHNY/2024[2014-15]Status: DisposedITAT Chennai06 Aug 2024AY 2014-15

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.329/Chny/2024 (िनधा9रणवष9 / Assessment Year: 2014-15) M/S. Smart Information Worldwide Inc. Dcit बनाम/ 49 Sixth Main Road, International Taxation -2(2) Vs. Raja Annamalaipuram, Chennai-600 028. Chennai-6. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaocs-8497-G (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओरसे/ Appellant By : Shri V. Ravichandran (Ca)- Ld.Ar " थ"कीओरसे/Respondent By : Shri Nilay Baran Som (Cit)-Ld. Sr. Dr सुनवाई की तारीख/Date Of Hearing : 20-06-2024 घोषणा की तारीख /Date Of Pronouncement : 06-08-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

For Appellant: Shri V. Ravichandran (CA)- Ld.ARFor Respondent: Shri Nilay Baran Som (CIT)-Ld. Sr. DR

Section 143(3)Section 195Section 48Section 50CSection 50D

share disregarding the agreement value between the assessee and Norwest. However, the aforesaid valuation, in our opinion, is clearly fallacious one since the valuation of shares would keep on fluctuating depending upon the performance of the underlying entity and the valuation could not be arrived merely on the basis

Shail Gas Pvt Ltd, Ghazaibad vs. Pr.CIT -7, New Delhi

In the result, the appeal of the assessee is allowed

ITA 630/DEL/2021[2015-16]Status: DisposedITAT Delhi05 Aug 2024AY 2015-16

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Akhilesh Kumar, Adv. &For Respondent: Ms. Sapna Bhatia, CIT-DR

Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 14ASection 263Section 56(2)(via)

thereof whereby assessee had a vested interest in Sanwariya Gas Ltd., as per scope and ambit of limited scrutiny, therefore the issue of valuation of shares with applicability of provisions of section 56(2)(viib) as raised in SCN u/s 263 being beyond the scope of “limited scrutiny” is also

Pathfinder Publishing Private Limited, Hyderabad vs. ACIT., Circle -16(2), Hyderabad

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

ITA 39/HYD/2024[2017-18]Status: DisposedITAT Hyderabad31 Jul 2024AY 2017-18

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri S.K. Gupta, AdvocateFor Respondent: : Ms. TH Vijaya Lakshmi, CIT-DR

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

provisions of Income Tax Act, 1961. 2. The Learned CIT(A) has erred in law and in fact in concluding that as per valuation of shares there is no justification of premium w.r.t the shares allotted, while the fact being that the company has duly followed the provisions ... rules prescribed for valuation of shares. 3. The Learned CIT(A) has erred in rejecting the Discounted Cash Flow method adopted by the company and justification filed to arrive at the fair market value of the shares. 4. The Learned CIT(A) has erred in applying the benefit of hindsight

DCIT-CC-5(3), Mumabi, Mumbai vs. Jwl Cold Store Private Limited, Panvel, Maharashtra

In the result, appeal of the revenue is dismissed

ITA 3098/MUM/2023[2014-15]Status: DisposedITAT Mumbai31 Jul 2024AY 2014-15

Bench: Shri Pavan Kumar Gadale, Hon’Ble & Shri Girish Agrawal, Hon’Ble

For Appellant: Shri Satish Mody, A/RFor Respondent: Ms. Rajeshwari Menon, Sr. D/R

Section 115JSection 143(3)Section 56(2)(viib)

assumptions and scenarios which were furnished by the management of assessee. However, ld. AO compared actual performance of assessee with projections adopted for valuation of shares. Assessee submitted that shares were issued in two tranches, one without premium and another at a premium of Rs.20/- per share, since its project ... 3098/Mum/2023 11 Bench in the case of Taaq Music Pvt. Ltd. [2020] SCC Online ITAT 9482, which held that, where assessee-company, for valuation of shares, placed reliance on valuation report drawn by a merchant banker wherein DCF method was adopted, AO could not have rejected said method and adopted

Income Tax Officer, Delhi vs. Toshiba Corporation, Gurgoan, Haryana

In the result, appeal of the Revenue is dismissed, being devoid of any merit

ITA 2532/DEL/2023[2016-17]Status: DisposedITAT Delhi26 Jul 2024AY 2016-17

Bench: Shri Vikas Awasthy & Shri Naveen Chandraआअसं.2532/िद"ी/2023 (िन.व. 2016-17) Income Tax Officer, International Taxation Ward-3(1)(1), ...... अपीलाथ"/Appellant Delhi 110002

For Appellant: Shri Vijay B Vasanta, CIT-DRFor Respondent: S/Shri Deepak Chopra, and Ankul Goyal, Advocates

Section 201Section 201(1)

applicable TDS on the long term capital gain arising in the hands of the sellers of the shares without appreciating the fact that valuation of shares by applying DCF method based on the premise of going concern of the company whose shares have been transacted in this case

The JCIT (OSD), Circle-2(1)(1), Ahmedabad vs. M/S. Magnet Buildtech P. Ltd, Ahmedabad

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

ITA 489/AHD/2020[2016-17]Status: DisposedITAT Ahmedabad25 Jul 2024AY 2016-17

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.489/Ahd/2020 "नधा"रण वष" /Assessment Year : 2016-17 The Jcit (Osd) M/S. Magnet Buildtech Pvt.Ltd. Circle-2(1)(1) बनाम/ 906-907, Indraprasth Corporate Ahmedabad Opp. Venus Atlantis V/S. Anand Nagar Road Ahmedabad – 380 015 "थायी लेखा सं./Pan: Aaicm 4158 J (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Vartik Chokshi & Shri Dhrunal Bhatt, Ars Revenue By : Shri Kamlesh Makwana, Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 23/07/2024 घोषणा क" तार"ख /Date Of Pronouncement: 25/07/2024 आदेश/O R D E R Per Shri Makarand V. Mahadeokar, Am: This Appeal Is Filed By The Revenue Against The Order Dated 09/07/2020 Passed By The Commissioner Of Income Tax (Appeals)-32, New Delhi [Hereinafter Referred To As “Cit(A)” In Short] Arising Out Of The Assessment Order Dated 11/12/2018 Passed By The Assessing Officer (Ao) Under Section 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As "The Act") Relevant To The Assessment Year (Ay) 2016-17. The Jcit (Osd) Vs. M/S.Magnet Buildtech Pvt.Ltd. Asst. Year : 2016-17

For Appellant: Shri Vartik Chokshi &For Respondent: Shri Kamlesh Makwana, CIT-DR

Section 133(6)Section 143(1)Section 143(2)Section 143(3)Section 56(2)(viib)

reply to the show-cause notice, the assessee submitted the valuation certificate, wherein the Valuer considered Discounted Cash Flow Method for valuation of shares in accordance with Rule 11UA of the Income Tax Rules. The AO observed that the Valuer has given some disclaimers in his certificates relating to financial ... JCIT (OSD) vs. M/s.Magnet Buildtech Pvt.Ltd. Asst. Year : 2016-17 adopted reasonable projections than the optimum figures for generation of revenue and the valuation of shares done by the valuer has got reasonable basis......". The Ld AR therefore, submitted that these reasons were also vague and cannot be grounds