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“DCF method”

Special Rate ProvisionsRule 11UARule 11UA318 judgments

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

Leading authorities on DCF method

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.

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.

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.

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.

Agro Portfolio (P.) Ltd. v. ITO
94 Taxmann.com 112 · 2018 · High Court
33
citing judgments

The Assessing Officer (AO) has the power to disturb the valuation of shares provided by the assessee's chartered accountant, even if Rule 11UA(2) is followed. If the AO doubts the valuation report, they are not necessarily bound to refer the matter to the Valuation Officer and can adopt a different method to determine the fair market value.

Cinestaan Entertainment (P) Ltd. v. ITO
106 Taxmann.com 300 · 2019 · High Court
28
citing judgments

An Assessing Officer must accept the fair market value of shares determined by the assessee using a prescribed method like DCF or NAV, and cannot substitute their own valuation, as Section 56(2)(viib) is a deeming provision not open to broad interpretation.

Agro Portfolio Pvt. Ltd. v. ITO
171 ITD 74 · 2018 · ITAT
27
citing judgments

The Assessing Officer can scrutinize the valuation report submitted by an assessee and may, if necessary, determine a fresh valuation using the Discounted Cash Flow (DCF) method, even if the assessee opted for a different method, provided the assessee fails to substantiate their projections.

Pr. Commissioner of Income Tax-2 v. Enrich Agro Food Products Pvt. Ltd.
148 Taxmann.com 26 · 2023 · High Court
20
citing judgments

The Delhi High Court confirms that when shares are issued at a premium to investors, the valuation of such shares must be assessed based on established methods like the NAV or DCF method, and the revenue cannot arbitrarily determine the fair market value.

Judgments citing DCF method

ACIT-2(2)(1), Mmumbai vs. M/S. Jics Logistic Limited, Mumbai

In the result, the appeal of the revenue for assessment year the appeal of the revenue for assessment year the appeal of the revenue for assessment year

ITA 1763/MUM/2023[2015-16]Status: DisposedITAT Mumbai29 Nov 2023AY 2015-16

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2011-12 & Assessment Year: 2012-13 &

For Appellant: Mr. Satyaprakash Singh

valuation of business of JICS Laboratories of JICS Laboratories two methods, firstly, by way of Discounted by way of two methods Discounted Cash Flow( DCF) method at Rs. 4287.30 lakhs and secondly, by way of Private DCF) method at Rs. 4287.30 lakhs and secondly, by way of DCF) method ... method DCF and PE method provided on behalf of the assessee provided on behalf of the assessee in the impugned orders. 5.1.2 For ‘DCF’ method method, the Valuer has projected the cash flow , the Valuer has projected the cash flow for next four years and then after applying discounting factor

ACIT-2(2)(1), Mmumbai vs. M/S. Jics Logistic Limited, Mumbai

In the result, the appeal of the revenue for assessment year the appeal of the revenue for assessment year the appeal of the revenue for assessment year

ITA 1762/MUM/2023[2014-15]Status: DisposedITAT Mumbai29 Nov 2023AY 2014-15

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2011-12 & Assessment Year: 2012-13 &

For Appellant: Mr. Satyaprakash Singh

valuation of business of JICS Laboratories of JICS Laboratories two methods, firstly, by way of Discounted by way of two methods Discounted Cash Flow( DCF) method at Rs. 4287.30 lakhs and secondly, by way of Private DCF) method at Rs. 4287.30 lakhs and secondly, by way of DCF) method ... method DCF and PE method provided on behalf of the assessee provided on behalf of the assessee in the impugned orders. 5.1.2 For ‘DCF’ method method, the Valuer has projected the cash flow , the Valuer has projected the cash flow for next four years and then after applying discounting factor

ACIT-2(2)(1), Mmumbai vs. M/S. Jics Logistic Limited, Mumbai

In the result, the appeal of the revenue for assessment year the appeal of the revenue for assessment year the appeal of the revenue for assessment year

ITA 1761/MUM/2023[2013-14]Status: DisposedITAT Mumbai29 Nov 2023AY 2013-14

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2011-12 & Assessment Year: 2012-13 &

For Appellant: Mr. Satyaprakash Singh

valuation of business of JICS Laboratories of JICS Laboratories two methods, firstly, by way of Discounted by way of two methods Discounted Cash Flow( DCF) method at Rs. 4287.30 lakhs and secondly, by way of Private DCF) method at Rs. 4287.30 lakhs and secondly, by way of DCF) method ... method DCF and PE method provided on behalf of the assessee provided on behalf of the assessee in the impugned orders. 5.1.2 For ‘DCF’ method method, the Valuer has projected the cash flow , the Valuer has projected the cash flow for next four years and then after applying discounting factor

ACIT-2(2)(1), Mmumbai vs. M/S. Jics Logistic Limited, Mumbai

In the result, the appeal of the revenue for assessment year the appeal of the revenue for assessment year the appeal of the revenue for assessment year

ITA 1760/MUM/2023[2011-12]Status: DisposedITAT Mumbai29 Nov 2023AY 2011-12

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2011-12 & Assessment Year: 2012-13 &

For Appellant: Mr. Satyaprakash Singh

valuation of business of JICS Laboratories of JICS Laboratories two methods, firstly, by way of Discounted by way of two methods Discounted Cash Flow( DCF) method at Rs. 4287.30 lakhs and secondly, by way of Private DCF) method at Rs. 4287.30 lakhs and secondly, by way of DCF) method ... method DCF and PE method provided on behalf of the assessee provided on behalf of the assessee in the impugned orders. 5.1.2 For ‘DCF’ method method, the Valuer has projected the cash flow , the Valuer has projected the cash flow for next four years and then after applying discounting factor

Sac Finance Comany Ltd, Hong Kong vs. ACIT, Circle International Taxation 3(1)(2), New Delhi

In the result appeal of the assessee in ITA no

ITA 2336/DEL/2022[2017-18]Status: DisposedITAT Delhi22 Nov 2023AY 2017-18

Bench: Shri Shamim Yahya & Shri Kul Bharatassessment Year: 2017-18

Section 143(3)Section 144CSection 144C(13)Section 48Section 92C

1 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “D”: NEW DELHI BEFORE SHRI SHAMIM YAHYA, ACCOUNTANT MEMBER AND SHRI

ITO Ward - 23(1), New Delhi vs. Sharp Eye Broadcasting Pvt Ltd, New Delhi

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

ITA 1105/DEL/2020[2016-17]Status: DisposedITAT Delhi20 Nov 2023AY 2016-17

Bench: Shri Saktijit Dey- & Shri Pradip Kumar Kedia-

For Appellant: Shri Arun Kumar, AdvFor Respondent: Shri Anuj Garg, Sr.DR
Section 143(3)Section 56(2)(viib)

report with effective date of valuation being 01.03.2016 wherein the FMV per share was assigned at Rs.102 per share by following Discounted Cash Flow (DCF) Method. The Assessing Officer however cast shadow on the propriety of FMV determined as per the valuation arrived in the valuation report and held such ... basis. 4.4 Before examining the fairness or reasonableness of valuation report submitted by the assessee, it has to be kept in mind that the DCF Method is essentially based on the projections (estimations) only and hence these projections cannot be compared with the actual to expect the same figures

Picture Time Digiplex Private Limited, New Delhi vs. ACIT Circle-19(2), New Delhi

ITA 7056/DEL/2019[2016-17]Status: DisposedITAT Delhi31 Oct 2023AY 2016-17

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmam/S. Picture Time Digiplex Vs. Acit, Private Limited Circle-19(2), B-19, Defence Colony, New Delhi South Delhi, New Delhi Pan: Aaicp2250Q (Appellant) (Respondent)

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

shares issued to residents and non-residents. The AO, thus questioning them u/s 56(2)(viib) of the Act, discredited the valuation of DCF method adopted by the assessee. The Assessee had relied a CBDT notification no. 45/16 dated 14.06.2016, giving exemption to start ups, which was not accepted

Breezefresh Dairy and Agro Farms Pvt. Ltd., New Delhi vs. ITO, Ward- 5(2), New Delhi

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

ITA 2151/DEL/2019[2015-16]Status: DisposedITAT Delhi27 Oct 2023AY 2015-16

Bench: Shri N.K. Billaiya & Shri Kul Bharat

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Shri Zafarul Haque Tanweer, CIT-DR
Section 56(2)(viib)

ground that the valuation of equity shares was based on the projections of the revenue which was not there. The assessee has applied DCF Method for the purpose of valuation of shares and has relied on the valuation report of an expert valuer. 20. There is a settled ... Income tax Rules, 1962, every assessee has an option to do valuation of shares and determine its Fair Market Value either by DCF method or NAV method, and that the Assessing Officer cannot examine or substitute his own value in place of the value so determined. The ITAT Delhi Bench

Osianama Learning Experience Pvt Ltd., Mumbai vs. Dy CIT 3 (2)(2), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 6796/MUM/2019[2013-14]Status: DisposedITAT Mumbai16 Oct 2023AY 2013-14
Section 143(3)Section 56Section 56(2)(viib)Section 59

assessee company filed a valuation report dated 15/09/2012 by an authorised valuer who had calculated the market value of the shares as per DCF method and determined the market value of the share @341/- per share. The details of the persons to whom shares were allotted as under:- Sr. Name ... valuation report submitted by the assessee, the value of the premium was determined at Rs.341/- per share which was worked out as per the DCF method and the working of which was as under:- INR IN MILLION 8. 1) Total present value of company 4305.0 operations 2) Plus Assets

Asst CIT 6 (2)(1), Mumbai vs. M/S Chiripal Poly Films Ltd., Mumbai

ITA 258/MUM/2020[2014-15]Status: DisposedITAT Mumbai11 Oct 2023AY 2014-15
For Appellant: Shri Tushar Hemani, Sr. AdvocateFor Respondent: Shri K.C. Selvamani
Section 115JSection 143(3)Section 56(2)(viib)Section 68

Appraisal Report) were same as the projections taken by the independent valuer to arrive at the value of INR 1,050/- per share using DCF Method which is one of the method notified by the Central Board of Direct Taxes (CBDT) vide Notification No. 52/2012, dated 29/11/2012 for the purpose ... Assessee and deleted the addition of INR 37,20,60,150/- under Section 68 of the Act. Further, the CIT(A) also concluded that DCF Method was one of the Method notified under Rule 11UA (2)(b) of the Rules and therefore, 13 CO No.152/Mum/2022 (Assessment Year

ACIT Circle-15(2), New Delhi vs. Lifestyle Probuild Pvt Ltd, Ghaziabad

In the result, this appeal by the Revenue stands dismissed

ITA 3552/DEL/2019[2015-16]Status: DisposedITAT Delhi09 Oct 2023AY 2015-16

Bench: AO; that valuation report dated 15.03.2012 prepared by the Chartered Accountant as per rule 11UA

For Appellant: Shri Gaurav Jain, AdvocateFor Respondent: Ms. Jyoti Verma, Sr. DR
Section 56(2)(viib)

share on the basis of book value method while the assessee has valued the share at Rs.1500/- per share on the basis of DCF method supported with valuation report. The AO has made an addition of Rs.2,43,32,640/- u/s 56(2)(viib) of the Income ... failed to appear to give personal deposition After considering the facts of the case, the AO rejected the valuation made by the valuer under DCF method and valued the share at Rs.196 per share being book value of shares and thus made the addition of differential amount as mentioned above

DCIT Circle-11(1), New Delhi vs. Hometrail Buildtech Pvt Ltd, New Delhi

In the result the appeal of the Revenue in ITA No

ITA 6095/DEL/2019[2015-16]Status: DisposedITAT Delhi15 Sept 2023AY 2015-16

Bench: Shri N.K. Billaiya & Shri Anubhav Sharma

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Vivek Kumar Upadhyay, Sr DR
Section 56(2)(viib)

crores made by the Assessing Officer u/s 56(2)(viib) of the Income-tax Act, 1961 [the Act, for short] holding that the DCF Method is the correct method for valuation of shares. 3. Representatives of both the sides were heard at length. Case records carefully perused. Relevant documentary evidence ... shares as on date of allotment. The assessee submitted Business Valuation Report dated 09.03.2015. The value of shares as per Discounted Cash Flow [DCF] Method is Rs. 15,988/-. 8. The Assessing Officer noticed that there was a huge difference between the financial projections and actual projections submitted

DCIT, CC-6(1), Mumbai vs. Neepa Real Estates Pvt Ltd., Mumbai

ITA 1041/MUM/2023[2012-13]Status: DisposedITAT Mumbai12 Sept 2023AY 2012-13

Bench: Shri Kuldip Singh & Shri Gagan Goyalassessment Years: 2012-13 The Deputy Commissioner M/S. Neepa Real Estates Of Income Tax, Pvt. Ltd., 12Th Floor, Hallmark Central Circle -6(1), Room No. 1905, Business Plaza, Vs. 19Th Floor, Sang Dnyaneshwar Marg, Air India Building, Near Gurunanak Hospital, Nariman Point, Bandra (E), Mumbai- 400 021 Mumbai- 400 051 Pan: Aaacn1884C (Appellant) (Respondent)

For Appellant: Dr. K. Shivaram, Sr. A.R. &For Respondent: Shri S. Srinivasu, D.R
Section 143(3)Section 147Section 148Section 153ASection 40Section 68

that the valuation of such shares was made at Rs.1,650/- per equity share as per valuation report by Chartered Accountant (CA) as per DCF method. The AO proceeded to hold that the assessee has received Rs.850/- premium on each share more than the assessed value of per share ... belong to Morgan Stanley Group. It is also not in dispute that valuation of the shares in question were made by CA by applying DCF method @ Rs.1650/- per equity share meaning thereby the assessee has received Rs.850/- per share more than the valuation made by CA. It is also

ACIT, Circle-8(1), New Delhi vs. Etawah Chakeri (Kanpur) Highway P.Ltd, New Delhi

In the result the appeal of the Revenue in ITA No

ITA 5906/DEL/2019[2013-14]Status: DisposedITAT Delhi12 Sept 2023AY 2013-14

Bench: Shri N.K. Billaiya & Shri Anubhav Sharma

For Appellant: Shri KVSR Krishna, CAFor Respondent: Shri T. James Singson, CIT- DR
Section 144ASection 56(2)(viib)

However, the CBDT, vide notification No 52/2012, dated 29.11.2012, amended Rule 11UA and inserted an option to the assessee either to choose NAV or DCF method for determination of fair market value. 9. The Assessing Officer noted that since the assessee has issued shares on 29.08.2012, prior to the date ... notification and insertion of DCF method, the assessee ought to have valued the fair market value of the shares by applying NAV method as, on the date of issue of shares, Rule 11UA did not provide for computation of fair market value as per DCF method. 10. Discarding the method

ACIT, Cir- 4(2)(1), Mumbai vs. M/S Innovage Fintech Pvt. Ltd., Mumbai

In the result, appeal of the Revenue is partly allowed for statistical purpose in the terms aforesaid

ITA 3068/MUM/2022[2017-18]Status: DisposedITAT Mumbai08 Sept 2023AY 2017-18

Bench: Shri Vikas Awasthy & Shri Om Prakash Kantm/S Innovage Fintech Pvt. Ltd. Acit, Circle-4(2)(1) 4-404, Krishna Residency, Opp Room No. 642, 6Th Floor, Radhakrishna Vidyalaya, Behind Vs. Aayakar Bhavan, M.K. Road, Sunder Nager, Malad (West), Mumbai-400020 Mumbai-400064 Pan No. Aacci3766N (Appellant) (Respondent)

For Appellant: Ms. Rutuja N. Pawar &For Respondent: Shri. K. C. Selvamani
Section 14ASection 56(2)(viib)

method specified in Rule 11UA. The said Rule prescribes determination of Fare Market Value [FMV] of shares on the basis of Discounted Cash Flow (DCF) method and the other method. The assessee in tune with Rule 11UA determined FMV following DCF method. The Valuation Report is at page

ADIT Infrapower & Multitrading Pvt Ltd, New Delhi vs. Pr. CIT, Gurgaon

In the result, the appeal of the assessee is dismissed

ITA 4944/DEL/2019[2014-15]Status: DisposedITAT Delhi05 Sept 2023AY 2014-15

Bench: Sh. C. M. Gargdr. B. R. R. Kumarita No. 4944 /Del/2019 : Asstt. Year : 2014-15 Adit Infrapower & Multitrading Pvt. Vs Pcit, Ltd., Da-08, 2Nd Floor, Vikas Marg, Gurgaon Shakarpur, New Delhi-110092 (Appellant) (Respondent) Pan No. Aahca5582H Assessee By : None Revenue By : Sh. P. Praveen Sidharth, Cit Dr Date Of Hearing: 10.08.2023 Date Of Pronouncement: 05.09.2023 Order Per Dr. B. R. R. Kumar:

For Appellant: NoneFor Respondent: Sh. P. Praveen Sidharth, CIT DR
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 263

appellant vide its submission dated 2nd December 2016 has submitted the copy of Fair valuation certificate pursuant to Discounted Free Cash Flow Method (DCF Method). 4. The Ld. PCIT has further stated in its order that Assessing Officer was required to examine and verify the credit worthiness of the subscriber

Nearbuy Pte.. Ltd, Singapore vs. ACIT (Intl Tax) Circle 3(3) (1), Mumbai

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

ITA 1607/MUM/2022[2018-19]Status: DisposedITAT Mumbai30 Aug 2023AY 2018-19

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

Section 143(3)

basis of valuation report obtained by it from M/s Finshore Management Services limited, who had valued the shares under Discounted Cash Flow (DCF) method and arrived at the value of Rs.7,094/- per share. It was further submitted that the Fair market value of shares is required to be determined ... worked out at a negative value of (-) Rs.630.29 per share, whereas the value of shares was arrived at Rs.7,094/- per share under DCF method. Accordingly, it was submitted that the sale consideration received by the assessee was more than the Fair Market Value and the same should be accepted

Bueno Foods Private Limited, New Delhi vs. ACIT Circle-5(1), New Delhi

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

ITA 9241/DEL/2019[2016-17]Status: DisposedITAT Delhi30 Aug 2023AY 2016-17

Bench: SHRI M. BALAGANESH (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

Section 143(3)Section 56(2)(viib)Section 68

addition made in the sum of Rs 2,73,55,743/- being share premium collected from angel investor as per Discounted Cash Flow (DCF) method valuation u/s 56(2)(viib) of the Act, in the facts and circumstances of the case. 3.1. The assessee company during the year under consideration ... three different dates in 2015. Assessee submitted a share valuation report wherein the fair market value of shares was determined using DCF method which is one of the prescribed method under Rule 11UA of the Income Tax Rules. The assessee was asked to justify the allotment of shares at premium

M/S. Doit Creations (India) Pvt. Ltd, Mumbai vs. Pr. Comm of Income Tax, Central Circle-3, Mumbai

In the result, the appeal of the assessee is partly allowed and additional ground of appeal filed by the assessee is dismissed

ITA 1354/MUM/2022[2015-16]Status: DisposedITAT Mumbai23 Aug 2023AY 2015-16

Bench: Shri Amit Shukla & Shri Amarjit Singhdoit Creations (India) Vs. Principal Commissioner Private Limited Of Income Tax, Central 307 & 308, 3Rd Floor,, Circle 3, Room No. 1901, Midas, Sahar Plaza, 19Th Floor, Air India Andheri (East) Building, Nariman Point, Mumbai – 400 069 Mumbai – 400 021 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aabcd8695A Appellant .. Respondent [ Appellant By : Dharan Gandhi Respondent By : Neena Jeph Date Of Hearing 27.07.2023 Date Of Pronouncement 23.07.2023 आदेश / O R D E R Per Amarjit Singh (Am): This Appeal Filed By The Assesse Is Directed Against The Order Passed By The Ld. Pcit(Central), Mumbai -3, Dated 31.03.2022 For A.Y. 2015-16. The Assessee Has Raised The Following Grounds Before Us: “1. On The Facts & Circumstances Of The Case & In Law, The Hon'Ble Pr.Cit Central - 3 (Herein After Referred As 'Pcit) Erred In Invoking Provisions Of Section 263 Of The Income Tax Act, 1961 (Hereinafter Referred As 'The Act') By Issuing The Notice Inspite Of The Fact That Assessment U/S. 143(3) & U/S 143(3) R.Ws 147 Of The Act Has Been Completed After Due Examination & Application Of Mind While Framing The Assessment Order U/S 143(3) & U/S 143(3) Rws 147 Of The Act. Further Order U/S 263 Is Also Passed Merely Setting Aside The Assessment To The File Of The Learned Assessing Officer To Conduct Proper Inquiry Which Is Unjustified. It Is Therefore Submitted That The Order Passed U/S 263 Should Be Cancelled.

For Appellant: Dharan GandhiFor Respondent: Neena Jeph
Section 143(3)Section 147Section 148Section 263Section 56(2)(viib)

equity shares of Rs.10/- at a premium of Rs.50 per shares. As per the valuation report fair value was calculated on Discounted Cash Flow (DCF method) and fair value of each equity shares as face value of Rs.10 was arrived at Rs. 60 per equity shares. It is also mentioned ... Shri Manoj Aggarwal of the Firm M/s Raj K Aggarwal & Associates As per the this report, fair value was calculated by Discounted Cash Flow(DCF) method and fair value of each equity shares of face value of Rs.10 was arrived at Rs.60.00 per equity share. On going through the valuation

Movefast Automobiles Pvt Ltd, Faridabad vs. ITO Ward - 1(5), Faridabad

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

ITA 6183/DEL/2019[2015-16]Status: DisposedITAT Delhi18 Aug 2023AY 2015-16

Bench: Shri C.M. Garg & Shri M. Balaganeshassessment Year: 2015-16 Movefast Automobiles Pvt. Ltd., Vs Ito, Ff-9, Vishnu Place, Ward-1(5), Near Neelam Flyover, Faridabad. Sector-20, Faridabad. Pan: Aaicm2607C

For Appellant: Shri Rajiv SaxenaFor Respondent: Ms Raja Rajeshwari R., Sr. DR
Section 133(6)Section 143(3)Section 56(2)(viib)Section 68

obtained a valuation report from a valuer who had arrived at the fair market value of the share using Discounted Cash-flow Method (DCF Method) in terms of Rule 11UA of the Rules. Hence, the alternative addition proposed by the ld. AO u/s 56(2)(viib ... fixed assets proving its intention to carry on any business in the near future, rejected the valuation report submitted by the assessee using DCF Method in terms of Rule 11UA of the Rules as suffering from defects. Accordingly, the ld.CIT(A) confirmed the addition made