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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

DCIT, Circle 3(1)(1), Bengaluru, Bmtc Building, Koramangala vs. Gtr Aluminium Private Limited, Bengaluru

In the result the appeal filed by the revenue is dismissed

ITA 165/BANG/2024[2015-16]Status: DisposedITAT Bangalore21 Nov 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2015-16

For Appellant: Sri Monish Sowkhar, A.RFor Respondent: Sri Balusamy N., D.R
Section 143(3)Section 250Section 253Section 263Section 56(2)(viib)

facts and circumstances of the case, the CIT(A) is right in law to hold the view that the method of share valuation (DCF method in this instance) adopted by the assessee cannot be changed even if the correctness of the result of the said method is doubted ... premium value as per section 56(2)(viib) r.w. rule 11UA of Income Tax Rules as per NAV. The appellant has calculated as per DCF method and submitted the chartered accountant report for the same. Hon'ble Bombay High Court in the case of Vodafone M-Pesa Ltd. v. PCIT

Signode India Limited, Hyderabad vs. ACIT, Circle-3(1), Hyderabad

ITA 240/HYD/2023[2015-16]Status: DisposedITAT Hyderabad14 Nov 2025AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: Shri H. SrinivasuluFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 143(3)Section 144C(5)Section 32

December 2012 and Provisional Financial Statement of Signode for the period 1 January 2013 to 30 June 2013 (“Historical Period”) 7.7 Under the DCF Method the growth rate is as under: 2013 2014 2015 2016 2017 2018 2019 Tv 6mts

Signode India Limited, Hyderabad vs. Deputy Commissioner of Income Tax, Circle-3(1), Hyderabad

ITA 434/HYD/2021[2016-17]Status: DisposedITAT Hyderabad14 Nov 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: Shri H. SrinivasuluFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 143(3)Section 144C(5)Section 32

December 2012 and Provisional Financial Statement of Signode for the period 1 January 2013 to 30 June 2013 (“Historical Period”) 7.7 Under the DCF Method the growth rate is as under: 2013 2014 2015 2016 2017 2018 2019 Tv 6mts

ACIT, Chennai vs. Updater Services Limited, Chennai

In the result, the grounds of appeal raised by both the assessee and the Revenue, as well as the grounds raised in the cross-objections filed by the assessee, are treated as allowed for statistical...

ITA 1616/CHNY/2025[2017]Status: DisposedITAT Chennai14 Nov 2025

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1339 /Chny/2025 िनधा#रण वष# / Assessment Year: 2017-18 M/S. Updater Services Limited (Formerly Dcit, Known As Updater Services Private Vs. Central Circle -2(3), Limited), No.2/302-A, Uds Salai, Chennai. Off Old Mahabalipuram Road, Thoraipakkam, Chennai – 600 097. [Pan:Aaacu-6845-J] (अपीलाथ%/Appellant) (&'थ%/Respondent)

For Appellant: Shri. K. Prasanna, C.AFor Respondent: Ms. E. Pavuna Sundari, C.I.T
Section 115QSection 250Section 263Section 391Section 77A

market value of the shares bought beck works out to INR 607 per share relying on a valuation carried out under "Discounted cash flow" (DCF) method. • As the consideration paid by the Company (ie, INR 275 per share) is less than the FMV of the shares bought back determined under ... DCF method, the learned AC proceeded with making an adjustment under Section 56(2)(viia) for the differential price. 2.1.1. Buy back of its own shares do not constitute 'property u/s 56(2)(va) • Section 56(2)(via) of the Act states that where a person receives any "property" without

M/S. Updater Services Ltd., Chennai vs. DCIT, Central Circle-2(3), Chennai

In the result, the grounds of appeal raised by both the assessee and the Revenue, as well as the grounds raised in the cross-objections filed by the assessee, are treated as allowed for statistical...

ITA 1339/CHNY/2025[2017-18]Status: DisposedITAT Chennai14 Nov 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1339 /Chny/2025 िनधा#रण वष# / Assessment Year: 2017-18 M/S. Updater Services Limited (Formerly Dcit, Known As Updater Services Private Vs. Central Circle -2(3), Limited), No.2/302-A, Uds Salai, Chennai. Off Old Mahabalipuram Road, Thoraipakkam, Chennai – 600 097. [Pan:Aaacu-6845-J] (अपीलाथ%/Appellant) (&'थ%/Respondent)

For Appellant: Shri. K. Prasanna, C.AFor Respondent: Ms. E. Pavuna Sundari, C.I.T
Section 115QSection 250Section 263Section 391Section 77A

market value of the shares bought beck works out to INR 607 per share relying on a valuation carried out under "Discounted cash flow" (DCF) method. • As the consideration paid by the Company (ie, INR 275 per share) is less than the FMV of the shares bought back determined under ... DCF method, the learned AC proceeded with making an adjustment under Section 56(2)(viia) for the differential price. 2.1.1. Buy back of its own shares do not constitute 'property u/s 56(2)(va) • Section 56(2)(via) of the Act states that where a person receives any "property" without

JCIT(OSD), New Delhi vs. Manish Vij, Delhi

In the result, the appeal of the revenue is dismissed

ITA 1746/DEL/2025[2022]Status: DisposedITAT Delhi14 Nov 2025

Bench: Shri C. N. Prasad & Shri M. Balaganeshjcit, Vs. Manish Vij, A-1,/ 134, 1St Floor, Sk (Osd), Delhi Enclave, South West Delhi (Appellant) (Respondent) Pan: Aagpv7555H

For Appellant: Shri Salil Aggarwal, AdvFor Respondent: Shri Mahesh Kumar, CIT (DR)
Section 143(3)Section 144BSection 48Section 50C

determined the fair market value of shares of CGPL as on 31.12.2021 to be Rs. 7,29,938/ shares by adopting Discounted Cash Flow (DCF) method. 5. The ld AO observed that within a gap of 11 months, the assessee was able to sell the 2nd lot of 595 shares ... this time, CGPL had already raised investments from venture capital firm and from foreign investors which warranted the valuation to be obtained by adopting DCF method as it is one of the prevalent method in foreign market and also one of the recognized methods in Rule 11UA of the Income

M/S. Ambattur Developers Pvt. Ltd., Chennai vs. ITO, Corporate Ward-1(1), Chennai

ITA 2601/CHNY/2024[2015-16]Status: DisposedITAT Chennai11 Nov 2025AY 2015-16

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 2601/Chny/2024 निर्धारण वर्ष / Assessment Year: 2015-16 M/S. Ambattur Developers Private Limited, (Amalgamated With Ambattur Hotels Private Limited) No. 86/E2, Industrial Estate, Ambattur, Chennai - 600 058. Tamil Nadu. [Pan: Aaeca-7490-D] (अपीलार्थी/Appellant) Income Tax Officer, Vs. Corporate Ward- 1(1), Chennai. (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By प्रत्यर्थी की ओर से/Respondent By : Shri. R. Vijayaraghavan, Advocate : Shri. Bipin, C.N., Cit सुनवाई की तारीख /Date Of Hearing घोषणा की तारीख/Date Of Pronouncement : 09.09.2025 : 11.11.2025 आदेश /Order Per S.R.Raghunatha, Am : This Appeal By The Assessee Is Filed Against The Order Of The Learned Commissioner Of Income Tax (Appeal), Nfac, Delhi, (In Short Ld.Cit(A)) For The Assessment Year 2015-16, Vide Order Dated 12.08.2024. 2. The Grounds Raised By The Assessee Are As Follows: :-2-:

For Respondent: Shri. R. Vijayaraghavan, Advocate
Section 50CSection 56(2)(vii)

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

M/S. Thiruvalluvar Textiles Pvt. Ltd., Rasipuram vs. ACIT, Central Circle-1(1), Chennai

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

ITA 1737/CHNY/2025[2017-18]Status: DisposedITAT Chennai04 Nov 2025AY 2017-18

Bench: Shri George George K & Shri S.R.Raghunatha

For Appellant: Shri. Y.Sridhar, FCAFor Respondent: Shri. Shiva Srinivas, CIT
Section 11

fact that as per rule 11 UA, option is given to the assessee to adopt one of the approved methods, either by NAV or DCF method. 7. The ld. CIT (A) ought to have appreciated the fact that share valuation report u/s 11 UA cannot be negated if facts ... towards share premium. During the assessment proceedings the Assessing Officer questioned on this quantification of share premium, the assessee submitted that they have followed DCF method for arriving at the value of Shares at Rs.501.28 per share on the date of allotment and valuation is supported by a certificate from

M/S. Thiruvalluvar Textiles Pvt. Ltd., Rasipuram vs. ACIT, Central Circle-1(1), Chennai

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

ITA 1736/CHNY/2025[2016-17]Status: DisposedITAT Chennai04 Nov 2025AY 2016-17

Bench: Shri George George K & Shri S.R.Raghunatha

For Appellant: Shri. Y.Sridhar, FCAFor Respondent: Shri. Shiva Srinivas, CIT
Section 11

fact that as per rule 11 UA, option is given to the assessee to adopt one of the approved methods, either by NAV or DCF method. 7. The ld. CIT (A) ought to have appreciated the fact that share valuation report u/s 11 UA cannot be negated if facts ... towards share premium. During the assessment proceedings the Assessing Officer questioned on this quantification of share premium, the assessee submitted that they have followed DCF method for arriving at the value of Shares at Rs.501.28 per share on the date of allotment and valuation is supported by a certificate from

M/S.Thiruvalluvar Textiles Pvt. Ltd., Rasipuram vs. ACIT, Central Circle-1(1), Chennai

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

ITA 1735/CHNY/2025[2014-15]Status: DisposedITAT Chennai04 Nov 2025AY 2014-15

Bench: Shri George George K & Shri S.R.Raghunatha

For Appellant: Shri. Y.Sridhar, FCAFor Respondent: Shri. Shiva Srinivas, CIT
Section 11

fact that as per rule 11 UA, option is given to the assessee to adopt one of the approved methods, either by NAV or DCF method. 7. The ld. CIT (A) ought to have appreciated the fact that share valuation report u/s 11 UA cannot be negated if facts ... towards share premium. During the assessment proceedings the Assessing Officer questioned on this quantification of share premium, the assessee submitted that they have followed DCF method for arriving at the value of Shares at Rs.501.28 per share on the date of allotment and valuation is supported by a certificate from

M/S. Thiruvalluvar Textiles Pvt. Ltd., Rasipuram vs. ACIT, Central Circle-1(1), Chennai

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

ITA 1734/CHNY/2025[2013-14]Status: DisposedITAT Chennai04 Nov 2025AY 2013-14

Bench: Shri George George K & Shri S.R.Raghunatha

For Appellant: Shri. Y.Sridhar, FCAFor Respondent: Shri. Shiva Srinivas, CIT
Section 11

fact that as per rule 11 UA, option is given to the assessee to adopt one of the approved methods, either by NAV or DCF method. 7. The ld. CIT (A) ought to have appreciated the fact that share valuation report u/s 11 UA cannot be negated if facts ... towards share premium. During the assessment proceedings the Assessing Officer questioned on this quantification of share premium, the assessee submitted that they have followed DCF method for arriving at the value of Shares at Rs.501.28 per share on the date of allotment and valuation is supported by a certificate from

Mount Spring Beverages Private Limited, New Delhi vs. ITO, Ward-17(2), Delhi

The appeal of the assessee is allowed for statistical purposes

ITA 188/DEL/2024[2013-14]Status: DisposedITAT Delhi31 Oct 2025AY 2013-14

Bench: Shri Anubhav Sharma & Shri Amitabh Shuklaassessment Year : 2013-14 Mount Spring Beverages Pvt Ltd., Vs. Ito, 9 Sainik Farms, Lane-C-3, Ward-17(2), Khanpur, Delhi. New Delhi - 110 080. Pan: Aafcm2918K Assessee By : Shri Aman Pawar, Advocate Revenue By : Ms Ankush Kalra, Sr. Dr Date Of Hearing : 13.10.2025 Date Of Pronouncement : 31.10.2025

For Appellant: Shri Aman Pawar, AdvocateFor Respondent: Ms Ankush Kalra, Sr. DR
Section 246A

investors, who after appraisal of the projects and its prospects mutually negotiated the price, after independent Valuation of the Shares using DCF method, certified by a Chartered Accountant. The book value of the shares as per audited accounts as on 31.3.2012 was Rs 0 due to accumulated losses

Savegenie E-Marketing Private Limited, Gurgaon vs. ITO, Ward-4(1), Gurgoan

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

ITA 3847/DEL/2024[2015-16]Status: DisposedITAT Delhi27 Oct 2025AY 2015-16

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Mukesh Mittal, CAFor Respondent: Shri Manish Gupta, Sr. DR
Section 139(1)Section 143(3)Section 147Section 148Section 56(2)(vii)Section 68

Section 56(2)(vii)(b) read with sub-rule (2) of Rule 11UA of the Income Tax Act on Discounted Cash Flow (DCF) method on the basis of a valuation report from a Chartered Accountant firm. The AO rejected the valuation report of the computation of fair value ... option to determine the fair market value of shares to be issued either on NAV method (sub-rule (2)(a)) or the DCF Method (sub-rule (2)(b)), and the Assessing Officer cannot substitute his own value in place of value so determined. 12. The ld. counsel for the assessee

A B Propmart Pvt Ltd, New Delhi vs. ITO Ward 1(1), Delhi

In the result, appeal of the assessee is allowed

ITA 108/DEL/2025[2014-15]Status: DisposedITAT Delhi15 Oct 2025AY 2014-15

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Assessment Year : 2014-15] A B Propmart Pvt.Ltd., Vs Ito, Punjabi Bhawan, 10 Ward-1(1), Rouse Avenue, Delhi-110002. Delhi Pan-Aagca7340G Appellant Respondent Assessee By Shri Chandan Agarwal, Ca & Shri Ajay Marwah, Ca Revenue By Shri Ajay Kumar Arora, Sr. Dr Date Of Hearing 17.07.2025 Date Of Pronouncement 15.10.2025 Order

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

valuation and determine FMV on the basis of either the DCF or NAV Method. The Respondent- Assessee being a start-up company adopted DCF method to value its shares. This was carried out on the basis of information and material available on the date of valuation and projection of future

Kataria Snack Pellets Private Limited, Rajkot vs. Assistant Commissioner of Income Tax, Circle-1(1), Rajkot

In the result, appeal of the assessee is dismissed

ITA 468/RJT/2024[2015-16]Status: DisposedITAT Rajkot07 Oct 2025AY 2015-16

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.468/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2015-16 Kataria Snack Pellets Pvt. Ltd. The Acit, Circle-1(1) बनाम 510, Gidc, Metoda Kalawad Road Rajkot Rajkot-360021, Gujarat Vs. Pan : Aafck2028L (अपीलाथ"/Appellant) (""यथ"/Respondent) :

For Appellant: Shri Nishit B. Jesur, ld.ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 143(2)Section 143(3)Section 147Section 148Section 250Section 56(2)(vii)

matter was referred to Department's Valuation Officer. In view of above, Hon`ble ITAT held that Assessing Officer was justified in rejecting DCF method and to determine FMV of shares. Thus for the reasons as stated above and discussed at length, the valuation report dated 01.02.2015 valuing the value ... following Discounted Cash Flow method, however the same is not reflected in the future assessment year for which assessee has made projections in the DCF method. The Assessee contended that it can opted any of the methods of valuations are given under the 11UA of the Income Tax Rules

Ideaforge Technology Ltd, Mahape vs. ACIT, Circle 15(2)(1), Mumbai

The appeal of the assessee is allowed

ITA 867/MUM/2025[2017-18]Status: DisposedITAT Mumbai26 Sept 2025AY 2017-18

Bench: Shri Narender Kumar Choudhry & Smt. Renu Jauhriआयकर अपील सं./Ita No. 867/Mum/2025 (निर्धारण वर्ा / Assessment Year: 2017-18) Ideaforge Technology V/S. Assistant Commissioner Ltd. बिधम Of Income Tax, Circle El-146, Ttc Industrial 15(2)(1), Mumbai Area, Electronic Zone, Room No. 357, 3Rd Floor, Midc, Mahape, Navi Aayakar Bhavan, Maharshi Mumbai Karve Road, Mumbai 400020 स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No: Aabci6495B Appellant/अपीलधथी .. Respondent/प्रनिवधदी निर्धाररिी की ओर से /Assessee By: Shri Subodh Ratnaparkhi Shri. Leyaqat Ali Aafaqui (Sr Dr) रधजस्व की ओर से /Revenue By: सुिवधई की िधरीख / Date Of Hearing 22.08.2025 घोर्णध की िधरीख/Date Of Pronouncement 26.09.2025 आदेश / O R D E R Per Renu Jauhri [A.M.] :- This Appeal Is Filed By The Assessee Against The Order Of The National Faceless Appeal Centre (Nfac), Delhi [Cit(A)] Dated 11.12.2024, Passed U/S. 250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “Act”] For Assessment Year [A.Y.] 2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal: “On The Facts & In Law, 1. The Hon. Cit(A) Erred In Upholding The Action Of The Id Ao In Making Addition Of Rs. 6,60,02,100/- By Relying Upon The Provisions Of Section 56(2)(Viib) Of The It Act, 1961 On The Ground That The Consideration Received By The Appellant For Issue Of P A G E | 2

For Appellant: Shri Subodh Ratnaparkhi
Section 143(3)Section 250Section 56(2)(viIb)Section 56(2)(viib)

Ideaforge Technology Ltd. unquoted shares exceeded the fair market value of such shares, disregarding the valuation as per Discounted Cash Flow (DCF) Method adopted by the appellant by relying upon Rule 11UA(2)(b) but instead applying Net Asset Value (NAV) method, which being not justified, the addition of Rs.6 ... lower authorities that the issue of 4700 equity shares during the year was based on accountants report, considering the projected future income as per DCF method. The appellant company submitted detailed explanation alongwith documentary evidences before Id.AO. The Id.AO failed to appreciate that valuation for issue of shares was based

DCIT Circle-13(2), New Delhi vs. Jus Scriptum Magnus Pvt Ltd, New Delhi

In the result, we dismiss the appeal filed by the Revenue

ITA 8259/DEL/2019[2016-17]Status: DisposedITAT Delhi26 Sept 2025AY 2016-17
For Appellant: Shri Pramod Jain, CAFor Respondent: Shri Harpreet Kaur Hansra, Sr. DR
Section 133(6)Section 143(2)Section 56(2)(viib)

satisfied, then we do not find any express provision under the Act or rules, where Assessing Officer can adopt his own valuation in DCF method or get it valued by some different Valuer. There has to be some enabling provision under the Rule or the Act Where Assessing Officer ... assets based NAV method which is based on actual numbers as per latest audited financials of the assessee company. Whereas in a DCF method, the value is based on estimated future projection. These projections are based on various factors and projections made by the management and the Valuer, like growth

Pranoo Financial Services Private Limited, Mumbai vs. DCIT, Circle 13(1)(2), Mumbai

ITA 4580/MUM/2025[2017-18]Status: DisposedITAT Mumbai24 Sept 2025AY 2017-18

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Vipul Joshi & Ms. Sruti KalyanikarFor Respondent: Shri Virabhadra S. Mahajan
Section 143(3)Section 250Section 56(2)(viib)

Fair Market Value of unquoted shares taking book value as the basis or fair market value as determined using Discounted Free Cash Flow (DCF) method. It was explained before the Assessing Officer that the Assessee-Company had opted for fair market valuation based upon DFC Method and in 4 Assessment ... contention of the Assessee is that the Assessee had issued shares at a premium by adopting the Fair Market Value determined using DCF Method as prescribed in the applicable Rule 11UA of the IT Rules and therefore, no addition was warranted under Section 5 Assessment Year

Income Tax Officer, New Delhi vs. Nine Plus Inftrastructure Private Limited, Gurgaon

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

ITA 4887/DEL/2024[2015-16]Status: DisposedITAT Delhi19 Sept 2025AY 2015-16

Bench: Shri Madhumita Roy & Shri Amitabh Shukla

For Appellant: Shri S.N.Devatia, AdvFor Respondent: Shri Manoj Tiwari, Sr.DR
Section 143(3)Section 56Section 56(2)(viib)

price of the shares at a premium of Rs. 190/- was based on valuation as per rule 11 UA by an accountant as per DCF method. The Ld.AO noted the deficiencies in the valuation adopted by the assessee and proceeded to reject the DCF method adopted by the appellant ... impugned addition by rejecting the valuation report produced by the assessee. It is pertinent to note that the appellant assessee had adopted the DCF method prescribed in Rule 11UA, whereas the Ld.AO proceeded to make the valuation by substituting the valuation of shares by adopting fair market value

Assistant Commissioner of Income Tax, Corporate Circle-3(1), Chennai vs. Schneider Electric Systems India Private Limited, Chennai

In the result all the four appeals of the Assessee and both the appeals of the revenue are partly allowed

ITA 2959/CHNY/2024[2016-17]Status: DisposedITAT Chennai11 Sept 2025AY 2016-17

Bench: Shri George George K & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.: 2754, 2755, 2756 & 2757/Cnny/2024 धनिाजरण वर्ज / Assessment Year: 2015-16, 2016-17, 2017-18, 2018-19 & Sa 22/Chny/2025 [In Ita 2757/Chny/2024] धनिाजरण वर्ज / Assessment Year: 2018-19 Schneider Electric Systems Acit India Private Limited, Vs. Corporate Circle 3(1) Sp Plot, 16-20 & 20A, Chennai. Tamarai Tech Park, Inner Ring Road, Thiru Vi Ka Industrial Estate, Guindy, Chennai – 600 032. [Pan: Aabcs-8027-M] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) आयकर अपील सं./Ita Nos.: 2958 & 2959/Chny/2024 धनिाजरण वर्ज / Assessment Year: 2015-16, 2016-17 Acit Schneider Electric Systems India Private Limited, Corporate Circle 3(1) Vs. Chennai. Sp Plot, 16-20 & 20A, Tamarai Tech Park, Inner Ring Road, Thiru Vi Ka Industrial Estate, Guindy, Chennai – 600 032. [Pan: Aabcs-8027-M] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) धनिाजररती की ओर से/Assessee By : Shri. Rohit Tiwari, Advocate & Ms. Tanya, Advocate (Virtual) राजस्व की ओर से /Revenue By : Shri. Arv Sreenivasan, Cit.

For Appellant: Shri. Rohit Tiwari, Advocate &For Respondent: Shri. ARV Sreenivasan, CIT
Section 143(1)Section 250

transaction of sale of ACD segment by itemizing assets for determination of arm’s length price. Further, the TPO seem to have disregarded the DCF method and the certified valuation report furnished by Assessee. The TPO has accepted the book value of all assets except land and building ... method, the TPO cannot make any adjustment. 18. The Ld. DR contended that since the division was incurring continuous losses, the valuation as per DCF method should not be accepted. Further, the Ld.DR also contended that the transaction has been declared as a deemed international transaction because the present transaction