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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 Ltu Circle 1 Chennai, Chennai vs. Prudential Sugar Corporation Limited, Chitoor

ITA 2298/CHNY/2024[2018-19]Status: DisposedITAT Chennai17 Jul 2025AY 2018-19

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:2298/Chny/2024 िनधा"रण वष" / Assessment Year: 2018-19 The Assistant Commissioner Of Prudential Sugar Corporation Income Tax, Vs. Limited, Ltu, Circle -1, Prudential Nagar, Chennai. Koppedu Post, Nindra, Mandal – 517 587. [Pan:Aaacp-4338-D] (अपीलाथ"/Appellant) (""थ"/Respondent)

For Appellant: Ms. E. Pavuna Sundari, C.I.TFor Respondent: Shri. D. Anand, Advocate
Section 50Section 50B

crores respectively from various subscribers including the assessee. c) The valuation reports submitted by the assessee of M/s Sibasankar and Associates on the valuation of shares of these two companies at the time of purchase and sale of shares had no basis and did not explain

Tutor Investment& Finance Pvt Ltd, Mumbai vs. DCIT, Central Circle 6(4), Mumbai

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

ITA 1736/MUM/2025[2013-14]Status: DisposedITAT Mumbai10 Jul 2025AY 2013-14

Bench: the ITAT, Mumbai Bench “E”, which, vide its order in ITA No. 6752/Mum/2017 dated 15.06.2018, upheld the revisionary order passed under Section 263 of the Act.

For Appellant: Shri Snehal ShahFor Respondent: Shri Ritesh Misra, CIT DR
Section 143(3)Section 147Section 250Section 263Section 56Section 56(2)(vii)

assets, including intangible assets being goodwill etc whichever is higher. In the course of original assessment proceedings, the Appellant explained the valuation of shares on the basis of value of various non- current investment held by the Appellant which has been taken on its books value rather than its intrinsic

Assistant Commissioner of Income Tax, New Delhi vs. Archana Dalmia, Delhi

In the result, appeal of the Revenue is dismissed

ITA 3998/DEL/2024[2014-15]Status: DisposedITAT Delhi10 Jul 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shri S Rifaur Rahmanआअसं.3998/िद"ी/2024(िन.व. 2014-15) Assistant Commissioner Of Income Tax, Circle 52(1), 14Th Floor, E-2 Block Civic Centre, ...... अपीलाथ"/Appellant New Delhi 11002 बनाम Vs. Archana Dalmia, 3, Sikandra Road, Kalmia House, New Delhi ..... "ितवादी/Respondent Pan: Aagpd-7794-N Assessee By : S/Shri Kunal Agarwal, Chartered Accountant & Manish Agarwal, Advocate Department By: Shri Ashish Tripathi, Sr. Dr सुनवाई क" ितिथ/ Date Of Hearing : 16/04/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 10/07/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Revenue Is Directed Against The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [In Short ‘The Cit(A)] Dated 26.06.2024, For The Assessment Year 2014-15. 2. The Brief Facts Of The Case As Emanating From Records Are: The Assessee Sold 23,500 Shares Of Durga Enterprises P. Ltd., During The Period Relevant To Assessment Year Under Appeal To Pyramid Commodities (P) Ltd. (Unrelated Party) For A Total Consideration Of Rs.19,97,50,000/-. The Assessee Suffered Long Term

For Appellant: S/Shri Kunal Agarwal, Chartered Accountant &For Respondent: Shri Ashish Tripathi, Sr. DR
Section 132Section 132(4)Section 147Section 148Section 55(2)(b)

filed return of income on 24.08.2022 declaring total income of Rs.1,33,06,444/-. The assessee made detailed submissions regarding acquisition of shares, valuation of shares of M/s. Durga Enterprises P. Ltd. along with supporting share certificate, mode of acquisition and also sale of shares to PMC Fincorp ... substantiate the cost of acquisition of 6098 shares, the assessee had relied upon the certificate of chartered accountant dated 28.07.2013 determining the valuation of shares based on net asset method as on 01.04.1981. Kindly refer Page no 218 of the PB. The value of shares was determined at Rs.4645

Abusha Investment & Management Services LLP, Chennai vs. DCIT Non Corporate Circle 7(1), Chennai

In the result, appeal filed by the assessee is allowed

ITA 3417/CHNY/2024[2017-18]Status: DisposedITAT Chennai08 Jul 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

For Appellant: Mr.Bhabagrahi Dash, CAFor Respondent: Mr.Shiva Srinivas, CIT
Section 2(47)Section 250Section 45(1)Section 45(4)

आयकर अपीलीय अिधकरण, ‘बी’ "यायपीठ, चे"ई। IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH: CHENNAI "ी एबी टी. वक", "ाियक

Invesco(India) Private Limited, Hyderabad vs. DCIT, Circle -2 (1), Hyderabad

In the result, appeal of the Assessee is partly allowed for statistical purposes

ITA 111/HYD/2022[2017-18]Status: DisposedITAT Hyderabad30 Jun 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA, Sriram SeshadriFor Respondent: Shri B Bala Krishna, CIT-DR
Section 143(3)Section 144C(5)

each share works-out at Rs.81,635/- per share. Thus, for showing investment in shares, the assessee has adopted DCF method of valuation of shares and in order to record ‘goodwill’, the assessee has adopted fair market value of assets, both on the same date. The Assessing Officer ... different purposes, in our considered view, the argument of the assessee that, DCF method is the recognised method for the purpose of valuation of shares and the assessee has acquired shares as per DCF method is devoid of merits and cannot be accepted. In our considered view, whether assessee follows

Saumya Mittal, New Delhi vs. ACIT-1, Moradabad, Delhi

The appeal is allowed

ITA 3764/DEL/2024[2018-19]Status: DisposedITAT Delhi25 Jun 2025AY 2018-19

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year: 2018-19 Saumya Mittal, Vs Acit-1, C10, Kalindi Colony, Moradabad. New Delhi – 110 065. Pan: Achpm0134E (Appellant) (Respondent) Assessee By : Shri Ajay Wadhwa, Advocate; Ms Ragini Handa, Advocate; & Shri Saksham Garg, Ca Revenue By : Shri Manish Gupta, Sr. Dr Date Of Hearing : 02.06.2025 Date Of Pronouncement : 25.06.2025 Order Per Anubhav Sharma, Jm:

For Appellant: Shri Ajay Wadhwa, AdvocateFor Respondent: Shri Manish Gupta, Sr. DR
Section 143(2)Section 143(3)

father and receipt of Form SH 4 with share certificates at page 110 of PBK 5. DETAILS FILED IN RESPECT OF VALUATION OF SHARES OF EUBI i. Copy of ITR Acknowledgment of EUBI for A.Y 2017-18 to 2019-20 showing loss in all years referPage

Vinodbhai Laxmanbhai Pithiya, Vadodara vs. The Dy.CIT, Circle-1(1)(1) (Previously the ITO- Ward-1(2)(5)), Vadodara

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

ITA 919/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad18 Jun 2025AY 2016-17

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Ms. Kinjal Shah, C.AFor Respondent: Shri Hargovind Singh, Sr. DR
Section 131Section 131(1)Section 133ASection 26A

IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, AHMEDABAD BEFORE SMT. ANNAPURNA GUPTA, ACCOUNTANT MEMBER & SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER

Deputy Commissioner of Income Tax, Aurangabad vs. Ashish Jugalkishor Bhala, Jalna

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

ITA 1238/PUN/2024[2021-22]Status: DisposedITAT Pune16 Jun 2025AY 2021-22

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2021-22 Dcit, Aurangabad Ashish Jugalkishor Bhala Mamta Hospital, Shivaji Putla Road, Vs. Bharat Nagar, Jalna – 431203 Maharashtra Pan: Ahmpb3683K (Appellant) (Respondent) Assessee By : Shri Anand Partani Department By : Shri Ramnath P Murkunde Date Of Hearing : 01-04-2025 Date Of Pronouncement : 16-06-2025 O R D E R

For Appellant: Shri Anand PartaniFor Respondent: Shri Ramnath P Murkunde
Section 56(2)(x)

Method, Book Value Method and Market Value Method and after considering the weighted values as per the above-mentioned methods, the valuation of shares was arrived at Rs.522.48 per share. However, on perusal of provisions of section 50CA, the Assessing Officer noted that the valuation of shares for transfer purpose ... assessee had furnished second valuation report u/s 11UA (1)(c)(b) from Shri Vishal Holani, C.A. and he had arrived at the valuation of shares at Rs.643.80 & rounded it off to Rs.640/-. The first valuation report had determined the value of shares at Rs.752.50/-. The difference of Rs.112.50/- in first

Santanu Roy Income Tax Officer Ward 10(2), Kolkata vs. Bruck Pharma Private Limited, Mumbai

In the result, both appeals of the revenue are partly allowed for statistical purposes

ITA 372/KOL/2025[2022-23]Status: FixedITAT Kolkata16 Jun 2025AY 2022-23

Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI RAKESH MISHRA (Accountant Member)

For Appellant: Shri Priyavrat Gupta, ARFor Respondent: Shri P.N.Barnwal, CIT-DR

partly allowed for statistical purposes. 5. In respect of ITA No.372/Kol/2025, it is noticed that the issue is in regard to the valuation of shares adopted by the assessee. A perusal of the order of the ld. CIT(A) shows that the ld. CIT(A) has not pointed

Santanu Roy, Income Tax Officr Ward 10(2), Kolkata vs. Bruck Pharma Private Limited, Mumbai

In the result, both appeals of the revenue are partly allowed for statistical purposes

ITA 371/KOL/2025[2013-14]Status: FixedITAT Kolkata16 Jun 2025AY 2013-14

Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI RAKESH MISHRA (Accountant Member)

For Appellant: Shri Priyavrat Gupta, ARFor Respondent: Shri P.N.Barnwal, CIT-DR

partly allowed for statistical purposes. 5. In respect of ITA No.372/Kol/2025, it is noticed that the issue is in regard to the valuation of shares adopted by the assessee. A perusal of the order of the ld. CIT(A) shows that the ld. CIT(A) has not pointed

Triveni Knits Private Limited, Ludhiana vs. ITO Ward 1 (3), Ludhiana

ITA 246/CHANDI/2024[2013-14]Status: DisposedITAT Chandigarh09 Jun 2025AY 2013-14

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Shri Rajesh Mehru, CA and Shri Dev Mehru, CAFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR
Section 56(2)(vib)Section 56(2)(viib)Section 69

value of share. 2 5. Ld. AO has erred in calculating the fair market value of unquoted equity shares of the appellant company. Valuation of shares for the purpose of Section 56(2)(viib) of the Income Tax Act, 1961 has been incorrectly calculated

Avt Homes Private Limited vs. ITO Ward 1(1), Fbd

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

ITA 1427/DEL/2024[2016-17]Status: DisposedITAT Delhi04 Jun 2025AY 2016-17

Bench: Shri S.Rifaur Rahman

For Appellant: Shri Rajiv Saxena, AdvocateFor Respondent: Shri Sanjay Kumar, Sr. DR
Section 133(6)Section 142(1)Section 143(1)Section 145Section 68

That the Ld. CIT(A) NFAC has grossly erred in law as well as on facts in not appreciating the fact that valuation of shares was made in accordance with the Rule 11 UA(2)(a) of Income Tax Rules, 1962 i.e., Net Asset Value Method, which ... prescribed methods for valuation of shares." The above grounds of appeals are independent of and without prejudice to each other. - 7. Ld. AR of the assessee submitted filed written submissions which read as under :- - 5. "It is further pertinent to mention that during the course of assessment proceeding

Deputy Commissioner of Income Tax, Central Circle - 1(3), Chennai vs. M. Mahadevan, Chennai

ITA 1826/CHNY/2024[2019-20]Status: DisposedITAT Chennai30 May 2025AY 2019-20

Bench: Shri Ss Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1824/Chny/2024, Assessment Years: 2013-14 आयकर अपील सं./Ita No.1825/Chny/2024, Assessment Years: 2014-15 आयकर अपील सं./Ita No.1826/Chny/2024, Assessment Years: 2019-20 Deputy Commissioner Of Income Tax, Central Circle-1(3), Chennai. M.Mahadevan, No.24, Park Avenue Street, Shenoy Nagar, Chennai-600 030. [Pan: Aajpm5888R] (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By (प्रत्यर्थी/Respondent) : Shri G.Gireesh, C.A प्रत्यर्थी की ओर से /Revenue By : Ms.C.Vatchala, Cit सुनवाई की तारीख/Date Of Hearing : 08.04.2025 घोषणा की तारीख /Date Of Pronouncement : 30.05.2025 आदेश / Order Per Amitabh Shukla, A.M : The Below Mentioned Appeals Have Been Filed By The Appellant Revenue For Ay-2013-14, Ay-2014-15 & 2019-20 Contesting The Order Of Ld. First Appellate Authority Indicated Column-E, Herein Below:- S. No. A Appeal Nos. B Ays C Appellant D Cit(A) Order Details E Respondent F 1

For Respondent: Ms.C.Vatchala, CIT

आयकर अपीलीय अधिकरण, 'बी' न्यायपीठ, चेन्नई। IN THE INCOME TAX APPELLATE TRIBUNAL 'B' BENCH: CHENNAI श्री यस यस विश्वनेत्र रवि

Deputy Commissioner of Inocme Tax, Central Circle - 1(3), Chennai vs. M. Mahadevan, Chennai

In the result, the appeals of the Revenue are decided as under:-

ITA 1825/CHNY/2024[2014-15]Status: DisposedITAT Chennai30 May 2025AY 2014-15

Bench: Shri Ss Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1824/Chny/2024, Assessment Years: 2013-14 आयकर अपील सं./Ita No.1825/Chny/2024, Assessment Years: 2014-15 आयकर अपील सं./Ita No.1826/Chny/2024, Assessment Years: 2019-20

For Appellant: Shri G.Gireesh, C.AFor Respondent: Ms.C.Vatchala, CIT

against the alleged sale of share at Rs.100 / share indicated in the agreement dated 18.08.2018. The Ld. DR thus argued that the corresponding valuation of shares made by the assessee u/s 56(2)(x) of the Act r.w. rule-11UA(1)(c )(v) as on 31.07.2018 at Rs.11 / share ... M/s.Senthil and Associate was also not the correct report because the valuation was arrived at on the premise that “…the above valuation per share of INR 11 is based on the financial data provided by the management as on 31.07.2018 after giving effect to the business transfer agreement…”. The Ld.DR

Deputy Commissioner of Income Tax, Chennai vs. M. Mahadevan, Chennai

In the result, the appeals of the Revenue are decided as under:-

ITA 1824/CHNY/2024[2013-14]Status: DisposedITAT Chennai30 May 2025AY 2013-14

Bench: Shri Ss Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1824/Chny/2024, Assessment Years: 2013-14 आयकर अपील सं./Ita No.1825/Chny/2024, Assessment Years: 2014-15 आयकर अपील सं./Ita No.1826/Chny/2024, Assessment Years: 2019-20

For Appellant: Shri G.Gireesh, C.AFor Respondent: Ms.C.Vatchala, CIT

against the alleged sale of share at Rs.100 / share indicated in the agreement dated 18.08.2018. The Ld. DR thus argued that the corresponding valuation of shares made by the assessee u/s 56(2)(x) of the Act r.w. rule-11UA(1)(c )(v) as on 31.07.2018 at Rs.11 / share ... M/s.Senthil and Associate was also not the correct report because the valuation was arrived at on the premise that “…the above valuation per share of INR 11 is based on the financial data provided by the management as on 31.07.2018 after giving effect to the business transfer agreement…”. The Ld.DR

DCIT-CC-4(3), Mumbai vs. Era Realtors Private Limited, Mumbai

In the result, the ground No

ITA 3096/MUM/2023[2013-14]Status: DisposedITAT Mumbai30 May 2025AY 2013-14

Bench: Shri Pawan Singh, Hon'Bleshri Girish Agrawal, Hon'Ble

Section 132Section 143(2)Section 153ASection 254(1)Section 92C

learned CIT-DR for the revenue supported the order of assessing officer. The learned CIT-DR for the revenue submits that no valuation of shares was obtained by assessee before 16 issuance of preferential CCD in favour of investor. The learned CIT (Appeals) allowed relief to the assessee

ACIT Circle-28(1), New Delhi vs. Ajay Singh, New Delhi

In the result, appeal of Revenue is allowed for statistical purpose

ITA 912/DEL/2020[2015-16]Status: DisposedITAT Delhi30 May 2025AY 2015-16

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.912/िद"ी/2020(िन.व. 2015-16) Assistant Commissioner Of Income Tax, Circle 28(1), R. No. 1001, 10Th Floor, E-2, Block, Pratyaksh Kar Bhawan, Civic Centre, ...... अपीलाथ"/Appellant J L Nehru Marg, New Delhi 110002 बनाम Vs. Ajay Singh, B-1, Kalindi Colony, New Delhi 110065 ..... "ितवादी/Respondent Pan: Abjps-9222-J Assessee By : None Department By : Shri Javed Akhtar, Cit(Dr) सुनवाई क" ितिथ/ Date Of Hearing : 03.03.2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 30.05.2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Revenue Is Directed Against The Order Of Commissioner Of Income Tax (Appeals)-10, New Delhi (Hereinafter Referred To As 'The Cit(A)') Dated 06.12.2019, For Assessment Year 2015-16. 2. The Revenue In Appeal Has Assailed The Order Of Cit(A) By Raising Following Grounds:-

For Appellant: NoneFor Respondent: Shri Javed Akhtar, CIT(DR)
Section 147Section 56(2)(vii)Section 56(2)(viii)

have examined the orders of authorities below. The solitary dispute in this appeal is with regard to Fair Market Valuation of shares of Spicejet Ltd. purchased by assessee from Sri Kalanithi Maran. The assessee has purchased 110300753 equity shares from Sri Kalanithi Maran for a total consideration of Rs.1

Ashok Bricks Industries Private Limited, Belpahar R S vs. Asst Commissioner of Income Tax, Rourkela Circle

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

ITA 182/CTK/2025[2018-19]Status: DisposedITAT Cuttack26 May 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115JSection 143(3)Section 250Section 56(2)(viib)

viib) of the Income Tax Act, 1961 without providing reasonable opportunity to submit the valuation report in support of the valuation of shares. 2) That in the facts and circumstances of the case the Leamed NFAC, Delhi is not justified to simply dismiss the appeal filed by the assessee without

Sapphire Foods India Limited, Mumbai vs. DCIT, Circle 3(3)(1), Mumbai

In the result, the appeal is partly allowed

ITA 5399/MUM/2024[AY 2016-17]Status: DisposedITAT Mumbai23 May 2025

Bench: Shri Amit Shukla & Shri Prabhash Shankar

For Appellant: Ms. Aarti Sathe / Asavari Kadam, ARFor Respondent: Shri Vivek Perampurna (CIT DR)
Section 143(3)Section 147Section 148Section 292BSection 56(2)(viia)Section 56(2)(viib)

liable to be set aside. 11. The Ld. CIT(A) erred in holding that the Appellant failed to provide the basis of above valuation of shares purchased (by way of conversion of loan into equity shares) at Rs.16.29 per share since the Appellant failed to provide audited financial statements

The ACIT, Circle-2(1)(1), Ahmedabad vs. M/S. Intas Pharmaceuticals Ltd., Ahmedabad

Accordingly, this ground raised by the Revenue is dismissed

ITA 281/AHD/2021[2015-16]Status: DisposedITAT Ahmedabad21 May 2025AY 2015-16

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2015-16 Acit, Cir.2(1)(1) M/S.Intas Pharmaceuticals Ltd Vejalpur Vs Corporate House Ahmedabad. S.G. Highway Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L Asstt.Year : 2015-16 M/S.Intas Pharmaceuticals Ltd Acit, Cir.2(1)(1) Corporate House Vs Vejalpur S.G. Highway Ahmedabad. Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocae & Shri Parin Shah, Ar : Shri Ragnesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 28/04/2025 घोषणा क" तारीख /Date Of Pronouncement: 21/05/2025 आदेश आदेश/O R D E R आदेश आदेश

Section 115JSection 142(1)Section 143(2)Section 143(3)Section 144CSection 14ASection 35Section 36(1)(iii)Section 37Section 92C

Whether the CIT(A) has erred in law and on facts in not appreciating that non examination of the valuation of shares of the amalgamated company by the assessing officer while issuing certificate of no objection at the time of amalgamation does not bar the assessing officer from ever examining