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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

Assistant Commissioner of Income Tax, Circle-3.3.1, Mumbai vs. Shapoorji Pallonji Solar Holdings Pvt. Ltd., Mumbai

In the result, the appeal is dismissed

ITA 5135/MUM/2024[2021-22]Status: DisposedITAT Mumbai23 Jan 2026AY 2021-22

Bench: Shri Saktijit Dey & Shri Jagadishasst. Cit, Circle 3.3.1 Shapoorji Pallonji Solar Holdings Room No. 522, 5Th Floor, Pvt. Ltd. Aayakar Bhavan, M. K. Road, Vs. 41/44, Sp. Centre Minoo Desai Mumbai-400 020 Marg, Colaba, Mumbai-400 005 Pan/Gir No. Aagcp 3195 E (Appellant) : (Respondent) Appellant By : Shri Dharmesh Shah & Ms. Mitali Parekh Respondent By : Shri Arun Kranti Datta – Cit Dr Date Of Hearing : 13.01.2026 Date Of Pronouncement : 23.01.2026 O R D E R Per Saktijit Dey: The Captioned Appeal By The Revenue Arises Out Of Order Dated 29.07.2024, Passed By National Faceless Appeal Centre (‘Nfac’ For Short), Delhi, Pertaining To The Assessment Year (A.Y. For Short) 2021-22. 2. There Is Delay Of Four Days In Filing The Appeal. After Considering The Submissions Of The Parties, We Are Satisfied That The Delay In Filing The Appeal Was Due To Reasonable Cause. Hence, We Condone The Delay & Admit The Appeal For Adjudication On Merits. The Grounds Raised By The Revenue Are As Under: (I) "Whether On The Facts & In The Circumstances Of The Case, The Cit(A) Erred In Holding That Both The Assessing Officers In Their Remand Report Have Not Given Adverse Findings Against The Assessee On The Issue Of Long Term Capital Loss Carried Forward, When In Fact Both Of Them Have Categoricaly Disagreed With The Submissions Made By The Assessee."

For Appellant: Shri Dharmesh Shah &For Respondent: Shri Arun Kranti Datta – CIT DR

verification and offering his comments. In the second remand report, filed by the A.O., the comments with reference to the valuation of shares are as under: 3. Disallowance of carry forward of Long Term Capital Loss to the tune of Rs. 1,83,00,38,564/-. Comments ... determination of the value of shares by the independent valuer appointed by the assessee. Though, the department had enough opportunities to counter the valuation of shares as per assessee at various stages, such as, in course of first appellate authority and remand proceedings, the department failed to do so. Even

Assisstant Commissioner of Income Tax Corporate Circle 1 1, Chennai vs. Fl Smith Private Limited, Kanchipuram

ITA 1763/CHNY/2024[2017-18]Status: DisposedITAT Chennai21 Jan 2026AY 2017-18

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 1682/Chny/2024 & Co No.71/Chny/2024 (In Ita No.: 1682/Chny/2024) निर्धारण वर्ष / Assessment Year: 2015-16 Assistant Commissioner Of Income Tax, Corporate Circle-1(1) Chennai. Flsmidth Private Limited, Vs. 34Th Egatoor, Flsmidth House, Rajiv Gandhi Salai, Kelambakkam, Kanchipuram – 603 103. (अपीलार्थी/Appellant) [Pan: Aaacf-4997-N] (प्रत्यर्थी/Respondent/ Cross Objector) आयकर अपील सं./Ita Nos.: 1731 & 1763/Chny/2024 निर्धारण वर्ष / Assessment Years: 2014-15 & 2017-18 Assistant Commissioner Of Income Tax, Corporate Circle-1(1) Chennai. Flsmidth Private Limited, Vs. 34Th Egatoor, Flsmidth House, Rajiv Gandhi Salai, Kelambakkam, Kanchipuram – 603 103. [Pan: Aaacf-4997-N] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Department By : Shri. P.M.Kathir, Advocate & Shri S.P.Chidambaram, Advocate : Shri. A R V Sreenivasan, Cit. सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement आदेश /O Rder : 15.12.2025 : 21.01.2026 Per Bench: These Appeals Filed By The Revenue & Cross Objection Filed By The Assessee Are Arising Out Of Order Of The Commissioner Of Income Tax (Appeals)-16, Chennai (In Short “Ld.Cit(A)”) Against Orders U/S.143(3) R.W.S. 92Ca(3) R.W.S 144C Of The Income Tax Act, 1961 (Hereinafter The ‘Act') For The

For Respondent: Shri. P.M.Kathir, Advocate and
Section 143(3)Section 43(1)Section 43(6)

IN THE INCOME TAX APPELLATE TRIBUNAL 'D' BENCH, CHENNAI BEFORE SHRI MANU KUMAR GIRI, JUDICIAL MEMBER AND SHRI S. R

Assisstant Commissioner of Income Corporate Circle 1-1, Chennai vs. Fl Smidth Private Limited, Kanchipuram

ITA 1731/CHNY/2024[2014-15]Status: DisposedITAT Chennai21 Jan 2026AY 2014-15

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 1682/Chny/2024 & Co No.71/Chny/2024 (In Ita No.: 1682/Chny/2024) निर्धारण वर्ष / Assessment Year: 2015-16 Assistant Commissioner Of Income Tax, Corporate Circle-1(1) Chennai. Flsmidth Private Limited, Vs. 34Th Egatoor, Flsmidth House, Rajiv Gandhi Salai, Kelambakkam, Kanchipuram – 603 103. (अपीलार्थी/Appellant) [Pan: Aaacf-4997-N] (प्रत्यर्थी/Respondent/ Cross Objector) आयकर अपील सं./Ita Nos.: 1731 & 1763/Chny/2024 निर्धारण वर्ष / Assessment Years: 2014-15 & 2017-18 Assistant Commissioner Of Income Tax, Corporate Circle-1(1) Chennai. Flsmidth Private Limited, Vs. 34Th Egatoor, Flsmidth House, Rajiv Gandhi Salai, Kelambakkam, Kanchipuram – 603 103. [Pan: Aaacf-4997-N] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) Assessee By Department By : Shri. P.M.Kathir, Advocate & Shri S.P.Chidambaram, Advocate : Shri. A R V Sreenivasan, Cit. सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement आदेश /O Rder : 15.12.2025 : 21.01.2026 Per Bench: These Appeals Filed By The Revenue & Cross Objection Filed By The Assessee Are Arising Out Of Order Of The Commissioner Of Income Tax (Appeals)-16, Chennai (In Short "Ld.Cit(A)") Against Orders U/S.143(3) R.W.S. 92Ca(3) R.W.S 144C Of The Income Tax Act, 1961 (Hereinafter The 'Act') For The

For Respondent: Shri. P.M.Kathir, Advocate and
Section 143(3)Section 43(1)Section 43(6)

आयकर अपीलीय अधिकरण, 'डी' न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL 'D' BENCH, CHENNAI श्री मनु कुमार गिरि, न्यायिक

Assisstant Commisioner of Income Tax Corporate Circle 1 1, Chennai vs. Fl Smith Private Limited, Kanchipuram

ITA 1682/CHNY/2024[2015-16]Status: DisposedITAT Chennai21 Jan 2026AY 2015-16

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 1682/Chny/2024 & Co No.71/Chny/2024 (In Ita No.: 1682/Chny/2024) निर्धारण वर्ष / Assessment Year: 2015-16 Assistant Commissioner Of Income Tax, Corporate Circle-1(1) Chennai. Flsmidth Private Limited, Vs. 34Th Egatoor, Flsmidth House, Rajiv Gandhi Salai, Kelambakkam, Kanchipuram – 603 103. (अपीलार्थी/Appellant) [Pan: Aaacf-4997-N] (प्रत्यर्थी/Respondent/ Cross Objector) आयकर अपील सं./Ita Nos.: 1731 & 1763/Chny/2024 निर्धारण वर्ष / Assessment Years: 2014-15 & 2017-18 Assistant Commissioner Of Income Tax, Corporate Circle-1(1) Chennai. Flsmidth Private Limited, Vs. 34Th Egatoor, Flsmidth House, Rajiv Gandhi Salai, Kelambakkam, Kanchipuram – 603 103. [Pan: Aaacf-4997-N] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) Assessee By Department By : Shri. P.M.Kathir, Advocate & Shri S.P.Chidambaram, Advocate : Shri. A R V Sreenivasan, Cit. सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement आदेश /O Rder : 15.12.2025 : 21.01.2026 Per Bench: These Appeals Filed By The Revenue & Cross Objection Filed By The Assessee Are Arising Out Of Order Of The Commissioner Of Income Tax (Appeals)-16, Chennai (In Short “Ld.Cit(A)”) Against Orders U/S.143(3) R.W.S. 92Ca(3) R.W.S 144C Of The Income Tax Act, 1961 (Hereinafter The ‘Act') For The

For Respondent: Shri. P.M.Kathir, Advocate and
Section 143(3)Section 43(1)Section 43(6)

आयकर अपीलीय अधिकरण, 'डी' न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL 'D' BENCH, CHENNAI श्री मनु कुमार गिरि, न्यायिक

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

In the result, the appeal of the assessee is allowed

ITA 6182/DEL/2019[2015-16]Status: DisposedITAT Delhi21 Jan 2026AY 2015-16

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumar

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

Refiral Solutions Private Limited, Gurgaon vs. Income Tax Officer, Gurgaon

The appeal is partly allowed

ITA 8306/DEL/2025[2015-16]Status: DisposedITAT Delhi20 Jan 2026AY 2015-16

Bench: Sh. Satbeer Singh Godaraita No. 8306/Del/2025 : Asstt. Year: 2015-16 Refiral Solutions Pvt. Ltd., Vs Income Tax Officer, House No. 1789, Third Floor, Sector- Ward-3(5), 46, Gurgaon-122002 Gurgaon-1220088 (Appellant) (Respondent) Pan No. Aahcr0604D Assessee By: Sh. Parikshit Aggarwal, Ca Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 20.01.2026 Date Of Pronouncement: 20.01.2026 Order This Assessee’S Appeal For Assessment Year 2015-16 Arises Against The Addl./Jcit(A), Kolkata’S Din & Order No. Itba/Apl/S/250/2025-26/1081746005(1) Dated 14.10.2025, In Proceedings U/S 144 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Parikshit Aggarwal, CAFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 144Section 56(2)(viib)

Rule 11UA(2)(b) of the I.T. Rules, 1962. The high premium of Rs.5,990/- was determined on the basis of such valuation of shares. In view of the same, the assessing officer was not justified in making addition on this issue. In this regard, as already discussed above ... just as in paper. The share valuation is therefore rejected as being false, fabricated and based on unrealistic facts and figures. 5.10 Hence valuation of shares as on the date of issue of the shares are determined as prescribed in Rule 11UA(2)(a) of I.T. Rules (prevalent during

Hero Fincorp Limited, New Delhi vs. ACIT, Circle 11(1), Delhi, C.R. Building

ITA 2542/DEL/2024[2017-18]Status: DisposedITAT Delhi16 Jan 2026AY 2017-18

Bench: Shri Mahavir Singh, Vice Presdient (), Shri Satbeer Singh Godara & Shri Brajesh Kumar Singhआ.अ.सं/.I.T.A No.2542/Del/2024 निर्धारणवर्ष/Assessment Year:2017-18 Hero Fincop Ltd., 34 Community Centre, Basant Lok, Vasant Vihar, New Delhi-110057 बनाम Vs. Assistant Commissioner Of Income Tax, Circle-11(1) C. R. Building, New Delhi-110002 अपीलार्थी Appellant प्रत्यर्थी/Respondent Pan:Aaach0157J Assessee By Shri Rohit Jain, Adv., Shri Deepesh Jain, Adv. & Shri Himanshu Aggarwal Adv. Revenue By Ms. Pooja Swaroop, Cit(Dr) सुनवाईकीतारीख / Date Of Hearing: 14.01.2026 उद्घोषणाकीतारीख/Pronouncement On 16.01.2026 आदेश /Order Per Brajesh Kumar Singh, Am, The Assessee Is Engaged In The Business Of ‘Hire Purchase Leasing & Finance'. This Appeal Is Filed By The Assessee Against The Order Of National Faceless Appeal Center (Nfac)/(First Appellate Authority Hereinafter Referred As “Faa”), Delhi Dated 27.03.2024 Arising Out Of Assessment Order U/S 143(3) Of The Act Dated 29.12.2019For The Assessment Year 2017-18. 2. The Assessee Has Raised Following Grounds Of Appeal: “Disallowance Of Provision For Collection Charges -Rs. 9,75,00,000/-

Section 143(3)Section 154Section 251(1)Section 56(2)(viib)

above basis and noted that the real figures as per audited financial statements are not at all in tune with projections taken for valuation of shares and there was a huge mismatch between the revenue and the profit after tax. The AO held it to be a self- serving projection

Acid, Circle-5(1), Kolkata vs. Emami Realty Limited, Kolkata

ITA 1457/KOL/2024[2021-22]Status: DisposedITAT Kolkata12 Jan 2026AY 2021-22

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubey

Section 143(3)Section 194ISection 2Section 250Section 50CSection 56Section 56(2)Section 56(2)(x)

आयकर अपीलीय अधिकरण, कोलकाता पीठ, कोलकाता IN THE INCOME TAX APPELLATE TRIBUNAL “C”BENCH KOLKATA Before Shri Rajesh Kumar, Accountant

Prem Sagar Chopra, Mumbai vs. Income Tax Officer 16(1)(3), Mumbai

In the result, the ground No

ITA 4538/MUM/2025[2014-15]Status: DisposedITAT Mumbai29 Dec 2025AY 2014-15

Bench: Shri Pawan Singh & Shri Girish Agrawal(Physical Hearing) Prem Sagar Chopra (Since Ito - 16(1)(3) Mumbai, Deceased) Through Neelam Prem Vs Room No. 438, Aayakar Bhavan, M.K. Sagar Chopra (Wife), Road, Churchgate, Sagar Villa Road No. 12A, Jvpd Mumbai – 400020. Scheme, Juhu, Mumbai, Maharashtra – 400049. [Pan No. Aapps2469E] Appellant / Assessee Respondent / Revenue

Section 147Section 254(1)Section 68

crore which was received in the form of shares from Moti Sagar against family settlement. The assessing officer objected that valuation of shares is not available on record. The assessing officer also referred the detailed called in respect of Rs. 2.18 crore from Prem Sagar Bank Account. The assessing officer ... crore which was received in the form of shares from Moti Sagar against family settlement. We find that the assessing officer objected that valuation of shares is not available on record. It was also accepted that the assessee submitted the detail of capital account on account of family settlement wherein

DCIT(CC)-8(3), Mumbai vs. Varun Vimlesh Mehta, Mumbai

In the result, appeal filed by revenue stands dismissed

ITA 3728/MUM/2025[2012-13]Status: DisposedITAT Mumbai29 Dec 2025AY 2012-13

Bench: Smt. Beena Pillai () & Shri Makarand Vasant Mahadeokar ()

Section 143(3)Section 147Section 148Section 69A

Rs.10/- per share to as many as 49 investors at a premium of Rs.10/- per share. The Ld. AO has doubted the valuation of shares on the premise that the market value was much lower than the issue price LAW & HUSTI the financials of the company did not justify issue

Instakart Services Private Limited, Bangalore vs. ACIT, Special Range-3, Bangalore

In the result appeal of the Revenue is hereby dismissed

ITA 544/BANG/2025[2017-18]Status: DisposedITAT Bangalore18 Dec 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Ajay Vohra, Sr. Advocate and Ms. AnkitaFor Respondent: Shri Shivanad Kalakeri, CIT

Assessee in the form of brand value. This again is an argument without bringing on record any material to substantial that valuation of shares were done only because of value being ascribed to brand or goodwill or any intangibles. The valuation of shares

Instakart Services Private Limited, Bangalore vs. JCIT, Special Rang-3, Bangalore

In the result appeal of the Revenue is hereby dismissed

ITA 543/BANG/2025[2016-17]Status: DisposedITAT Bangalore18 Dec 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Ajay Voh

Assessee in the form of brand value. This again is an argument without bringing on record any material to substantial that valuation of shares were done only because of value being ascribed to brand or goodwill or any intangibles. The valuation of shares

DCIT CC -1(4), Bengaluru vs. Instakart Services Pvt Ltd, Bengaluru

In the result appeal of the Revenue is hereby dismissed

ITA 531/BANG/2025[2018-19]Status: DisposedITAT Bangalore18 Dec 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Ajay Voh

Assessee in the form of brand value. This again is an argument without bringing on record any material to substantial that valuation of shares were done only because of value being ascribed to brand or goodwill or any intangibles. The valuation of shares

DCIT, CC-1(4), Bengaluru vs. Instakart Services Pvt Ltd, Bengaluru

In the result appeal of the Revenue is hereby dismissed

ITA 530/BANG/2025[2017-18]Status: DisposedITAT Bangalore18 Dec 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Ajay Voh

Assessee in the form of brand value. This again is an argument without bringing on record any material to substantial that valuation of shares were done only because of value being ascribed to brand or goodwill or any intangibles. The valuation of shares

Instakart Services Private Limited, Bengaluru vs. ACIT, Central Circle-1(4), Bengaluru

In the result appeal of the Revenue is hereby dismissed

ITA 496/BANG/2025[2018-19]Status: DisposedITAT Bangalore18 Dec 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Ajay Voh

Assessee in the form of brand value. This again is an argument without bringing on record any material to substantial that valuation of shares were done only because of value being ascribed to brand or goodwill or any intangibles. The valuation of shares

Brawny Nivesh P.Ltd, New Delhi vs. ACIT, Central Circle-13, New Delhi

In the result, appeal of the assessee is partly allowed

ITA 571/DEL/2019[2015-16]Status: DisposedITAT Delhi17 Dec 2025AY 2015-16

Bench: Shri Mahavir Singh & Shri Brajesh Kumar Singh

Section 143Section 143(3)Section 3Section 47Section 56Section 56(2)(via)Section 56(2)(viia)

vila) of the Act, on account of purchase of shares of M/s Gain E Commerce (P) Ltd. without accepting the valuation of shares declared by the assessee is against the provisions of law and the addition made is arbitrary, excessive and illegal. 2. That on the facts ... Rs.20.39.400/- u/s 56(2) (viia) of the Act, on account of purchase of shares of M/S Kanti Commercial (P) Ltd. without accepting the valuation of shares declared by the assessee is against the provisions of law and the addition made is arbitrary, excessive and illegal.” ITA No.-571/Del/2019 Brawny

Aadarsh Surana, Chennai vs. Deputy Commissioner of Income Tax, Corporate Circle 1(1), Chennai

In the result, the appeal of the assessee is allowed

ITA 1840/CHNY/2025[2017-18]Status: DisposedITAT Chennai15 Dec 2025AY 2017-18
For Appellant: Shri. R.Venkata Raman, C.AFor Respondent: Shri. Shiva Srinivas, CIT
Section 142(1)Section 143(2)Section 143(3)Section 250Section 47Section 68

assessee is entitled to the exemption provided therein, and no addition can be made merely on account of revaluation of assets or valuation of shares. 128. The Panaji Bench of this Tribunal in ACIT v. Joe Marcelinho Mathias [2013] 143 ITD 132 (Panaji - Trib) has held as under

ITO 16(1)(5), Mumbai, Aayakar Bhavan Mumbai vs. Talentube Entertainment Pvt Ltd, Bandra West

In the result, the appeal of the assessee bearing ITA 5066/Mum/2025 is allowed for statistical purpose and the appeal of the revenue bearing ITA No

ITA 5279/MUM/2025[2012-13]Status: DisposedITAT Mumbai15 Dec 2025AY 2012-13

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Zaman Ali, AdvFor Respondent: Shri Hemanshu Joshi, SR DR
Section 143(1)Section 143(3)Section 250Section 68

verification of these investors and ultimately treated the entire share capital and premium as bogus, though no objection whatsoever was raised regarding the valuation of shares under the DCF method. Consequently, the Ld. AO made an addition of Rs.5,00,00,012/- under section 68 of the Act. Aggrieved

Talentube Entertainment Private Limited, Mumbai vs. Income Tax Officer Ward 16(1)(5), Mumbai

In the result, the appeal of the assessee bearing ITA 5066/Mum/2025 is allowed for statistical purpose and the appeal of the revenue bearing ITA No

ITA 5066/MUM/2025[2012-13]Status: DisposedITAT Mumbai15 Dec 2025AY 2012-13

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Zaman Ali, AdvFor Respondent: Shri Hemanshu Joshi, SR DR
Section 143(1)Section 143(3)Section 250Section 68

verification of these investors and ultimately treated the entire share capital and premium as bogus, though no objection whatsoever was raised regarding the valuation of shares under the DCF method. Consequently, the Ld. AO made an addition of Rs.5,00,00,012/- under section 68 of the Act. Aggrieved

Bhisma Realty Limited, Mumbai vs. Income Tax Officer, Central Building Mumbai

In the result, appeal of the assessee is allowed

ITA 5694/MUM/2025[2018-19]Status: DisposedITAT Mumbai11 Dec 2025AY 2018-19

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2018-19 Bhishma Realty Limited. Vs Dcit, Cc-1(4), 3Rd Floor, Sir Vithaldas Central Building Chambers, 16 Mumbai Mumbai 400020 Sanmarg Marg, Fort, Mumbai 400001 Pan: (Aaacb5995N) Appellant Respondent Present For: Appellant By : Ms. Neha Paranjpe, Ar Respondent By : Shri Leyaqat Ali Aafaqui, Sr. Dr Date Of Hearing : 17.11.2025 Date Of Pronouncement : 11.12.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of Cit(A) 47, Mumbai Vide Order No. Itba/Apl/S/250/2025- 26/1078523862(1) Dated 15.07.2025 Passed Against Assessment Order U/S. 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 03.02.2021 For Ay 2018-19. 2. The Sole Issue Raised In The Present Appeal Is In Respect Of Disallowance Made Under Section 14A R.W.R. 8D Of The Income-Tax Rules, 1962 (Hereinafter Referred To As ‘The Rules’) Of Rs. 20,06,2346/- Against Suomoto Disallowance Made By The Assessee Of Rs. 94,147/-.

For Appellant: Ms. Neha Paranjpe, ARFor Respondent: Shri Leyaqat Ali Aafaqui, Sr. DR
Section 143(3)Section 14A

quantum of exempt income earned during the year. Additionally, assessee had pointed out from its computation of income that expense relating to valuation of shares amounting to Rs. 2,23,627/- was added back while computing income from business. We note that ld. AO nowhere in the impugned assessment order