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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

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)

effectively having a difference of more than Rs. 200 crore. In view of these facts, the AO held that in the present case, the DCF method adopted by the assessee to value its shares was not correct. Further, the AO determined the value of the shares under Rule 11UA ... order. 12.12 The Ld. CIT(A) noted on the perusal of the reply of the assessee that favourable projections for valuing the shares under DCF method was made only to justify the excess valuation of the share and to issue such overvalued shares whose addresses are in other countries

Mannequin Pharmaceuticals Private Limited, Bhubaneswar vs. Income Tax Officer, Ward-1(1), Bhubaneswar

In the result, appeal of the assessee is allowed

ITA 586/CTK/2025[2016-17]Status: DisposedITAT Cuttack05 Dec 2025AY 2016-17

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No. 586/Ctk/2025 (नििाारण वर्ा / Assessment Year : 2016-17) Mannequin Pharmaceuticals Vs Ito, Ward-1(1), Bhubaneswar Private Limited B-26 & 26(1), Chandaka Industrial Estate 751024 Pan No. : Aajcm 6157 G (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri P.K Mishra, Advocate राजस्व की ओर से /Revenue By : Shri Vijay Singh, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 05/12/2025 घोषणा की तारीख/Date Of Pronouncement : 05/12/2025 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Of Ld.Cit(A), National Faceless Appeal Centre(Nfac), Delhi Dated 28.08.2025 For The Assessment Year 2016-17. 2. It Was Submitted By The Ld. Ar That The Only Issue In The Assessee’S Appeal Was In Respect Of The Validation Of The Share Market Value Of Rs.4,900/- Equity Shares. It Was Submission That The Assesse Had Allowed The Discounted Cash Flow Method At Provided In Rule 11 Ua Of The Act Of The Income Tax Rules. 3. It Was Submission That The Ld.Cit(A) Has Held That The Fair Market Value Of The Unquoted Equity Shares Was To Be Determined By Merchant Banker. It Was Submission That Consequently As The Dcf Method Valuation

For Appellant: Shri P.K Mishra, AdvocateFor Respondent: Shri Vijay Singh, Sr. DR
Section 56Section 56(2)

that the fair market value of the unquoted equity shares was to be determined by merchant banker. It was submission that consequently as the DCF Method valuation 2 had been prepared by Chartered Accountant and not by the Merchant Banker. The Ld.CIT(A) had confirmed the addition of Rs.84 ... 11UA w.e.f 24/05/2018 and the impugned assessment year 2016-17. In this year qualified chartered accountant was authorized to prepare valuation report under in DCF method. It was submission that in page 15 of the order of the Ld.CIT(A), the Ld.CIT(A) has extracted the valuation of the discounted