“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

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

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

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

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

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

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

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

Dhola Infra Projects Limited (Formerly Known As Navayuga Dhola Infra Projects Limited), Mumbai vs. ACIT., Circle-16(1), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 800/HYD/2024[2016-17]Status: DisposedITAT Hyderabad17 Oct 2024AY 2016-17

Bench: Shri Laliet Kumar, Hon’Bleassessment Year – 2016-17 Dhola Infra Projects Limited Vs. Asst.Commissioner Of Tax (Formerly Known As Navayuga Circle-16(1) Dhola Infra Projects Limited Hyderabad Mumbai Pan : Aadcn3696B (Appellant) (Respondent) Assessee By: Shri Paras S.Savla, Ld.Ar (Through Virtual Hearing) Revenue By: Shri U Mini Chandran, Ld.Dr Date Of Hearing: 17.10.2024 Date Of Pronouncement: 17.10.2024

For Appellant: Shri Paras S.Savla, Ld.ARFor Respondent: Shri U Mini Chandran, Ld.DR

Section 234DSection 244ASection 56(2)(viib)

upholding the action of the Assessing Officer in rejecting the valuation of shares determined by an independent account using Discounted Cash Flows Method (“DCF Method”) which is in accordance with Section 56(2)(viib) of the Act read with Rule 11UA of the Income Tax Rules, 1962 (“the rules ... assessee to its shareholders in the same pattern, the assessee instead of issuing shares on NAV method, issued shares on the basis of DCF method. The Ld.AR had drawn our attention to valuation report at Page No.52 of the paper book, on the basis of which, NAV valuation per share

Menzies Bobba Ground Handling Services Private Limited (Now Merged With Menzies Aviation Bobba(Bangalore)Private Limited), Hyderabad vs. DCIT Circle-5(1), Hyderabad

ITA 226/HYD/2021[2015-16]Status: DisposedITAT Hyderabad09 Oct 2024AY 2015-16

Bench: Shri Manjunatha G. & Shri K.Narasimha Chary

For Appellant: Shri Sriram Seshadri, ARFor Respondent: Shri Madan Mohan Meena, DR appeared for Shri Kumar Pranav, CIT -DR

Section 115JSection 142(1)Section 143(3)Section 263Section 80

Section 263 of the Act. 9. While drawing our attention to the show cause notice dated 4/3/2020, wherein it was stated that if the DCF method is wrong and the FMV is equal to the par value, then the assessee stands to a gain of Rs.24,72,45,262/- under ... Court, the same was approved, but instead of paying the shareholders at the par market value of Rs.6,43,137/-, the assessee resorted to DCF method to arrive at a value of Rs.1,54,510/- and thereby paid a sum of Rs.7,81,82,060/- to the shareholders and diverted

Ace Cabs Limited, Delhi vs. ACIT, Circle-1(2), Delhi, C R Building

In the result, appeal filed by the assessee is allowed

ITA 443/DEL/2024[2017-18]Status: DisposedITAT Delhi04 Oct 2024AY 2017-18

Bench: Shri Saktijit Dey, Hon’Ble & Shri S.Rifaur Rahmanace Cabs Limited, Vs. Acit, Circle 1 (2), 562, Silver Oak Lane, Delhi. M.G. Road, Ghitorni, Delhi – 110 030. (Pan : Aaica4494R) (Appellant) (Respondent) Assessee By : Shri Gaurav Jain, Advocate Ms. Bharti Sharma, Advocate Revenue By : Shri Kanv Bali, Sr. Dr Date Of Hearing : 23.07.2024 Date Of Order : 04.10.2024 Order Per S.Rifaur Rahman,Am: 1. This Appeal Has Been Filed By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals), New Delhi [“Ld. Cit(A)”, For Short]/ National Faceless Appeal Centre (Nfac) Dated 12.12.2023 For The Assessment Year 2017-18. 2. The Assessee Submitted An Application Under Rule 29 Of The Itat Rules For Admitting The Additional Evidences & The Contents Thereof Are Reproduced Below:-

For Appellant: Shri Gaurav Jain, AdvocateFor Respondent: Shri Kanv Bali, Sr. DR

Section 142(1)Section 143(2)

premium, the AO, during the entire assessment proceedings, primarily focused on the justification of high valuation of shares done by the assessee, correctness of DCF method adopted for the valuation, and the applicability of the provisions of Section 56(2)(viib) of the Act. (v) It is also important ... asking it to explain why, based on certain irregularities allegedly identified by the AO in the valuation report, the valuation of shares using the DCF method should not be rejected, and the NAV method should be utilized instead. (vii) The assessee filed its reply to the show cause notice

Apple Infra Build Pvt Ltd, Noida vs. ITO Ward - 3(1), New Delhi

In the result, the appeal preferred by the assessee is dismissed

ITA 9880/DEL/2019[2015-16]Status: DisposedITAT Delhi06 Sept 2024AY 2015-16

Bench: Shri Shamim Yahya & Ms. Madhumita Roym/S Apple Infra Build Pvt. Vs. Income Tax Officer, Ltd., Plot No. 24/32, Ward-3(1) Block-D, Sector- 63, New Delhi - 110075 Noida- 201301

For Appellant: NoneFor Respondent: Sh. Kanv Bali, Sr. D.R

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

equity shares face value of Rs. 10 each issued till date 56,500 value of each equity share of Rs 10 each under DCF Method (iii) The Valuer has adopted amount of borrowings al nil on valuation date i.e 15.03.2015, share actually this amount as on this date ... Considering the facts of the case, I am of the view that the AO has rightlyrejected the valuation of shares under DCF method In the case of Agro Portfolio (P)Ltd [2018] 94 taxmann.com 112 (Delhi Trib) Hon'ble ITAT Delhi has held that "Forall these reasons

Leela Tourism and Heritage Private Limited, New Delhi vs. A0-ACIT, Circle 15(1), Delhi

In the result, the appeal of the assessee is allowed

ITA 3685/DEL/2023[2016-17]Status: DisposedITAT Delhi05 Sept 2024AY 2016-17

Bench: Shri Pradip Kumar Kedia & Shri Yogesh Kumar Usassessment Year 2016-17

For Respondent: Shri Subhra Jyoti Chakraborty, CIT-DR

Section 143(3)Section 234BSection 271(1)(C)Section 56(2)(viib)

premise that investment held by foreign subsidiary in the form of ‘Hotel Residence AG in Switzerland’ has been incorrectly taken on market value using DCF method instead of book value. The value of investment by the Assessee in the subsidiary based on replaced value of Hotel premises is uncalled ... change in the building plan and purposes, the value of the hotel building stands at Rs.51.52 crore based on potential earning by adopting DCF method of valuation of shares in 100% of wholly owned subsidiary. The CIT(A) observed that such methodology adopted by the assessee is not supported

Sparsh Beauty Care Pvt. Ltd., Haryana vs. ITO Ward-2(4), Haryana

In the result, the appeals of the assesses are allowed

ITA 86/DEL/2021[2016-17]Status: DisposedITAT Delhi05 Sept 2024AY 2016-17

Bench: Dr. B. R.R. Kumar & Sh. Sudhir Kumarassessment Year: 2016-17 M/S. Punyah Building Vs Ito Materials Pvt. Ltd. Ward-2 (1) House No.1002, Near Talab Faridabad Shiv Colony, Old Faridabad Haryana Ballahgarh Haryana 122002 Pan No.Aagcp8742B (Appellant) (Respondent) Assessment Year: 2016-17 Sparsh Beauty Care Pvt. Ltd. Vs Ito Plot No.1066, Near Janta Barat Ward-2 (4) Ghar Baba Nagar, Faridabad Faridabad Haryana 121002 Haryana Pan No.Aascs2575D (Appellant) (Respondent) Assessment Year: 2016-17 Speedy Courier Services Pvt. Vs Ito Ltd. Ward- 2 (4) Plot No.1022, Near Talab Shiv Faridabad Colony, Faridabad Haryana Pan No.Aascs2579R (Appellant) (Respondent)

Section 131oSection 142(1)Section 143Section 143(2)Section 143(3)Section 251(1)Section 271(1)(c)Section 56(2)(viib)Section 68

wherein it is held that the Assessing Officer cannot examined or substituted its own value in place of valuation arrived by the assessee either DCF Method or NAV Method, the commercial expediency has to be seen from the point view of businessman. Further held that if law provides the assessee ... Discounted Free Cash Flow method." 30. Ergo, the assessee has an option to do the valuation and determine the fair market value either on DCF Method or NAV Method. The assessee being a 'start-up company' having lot of projects in hand had adopted DCF method to value its shares

Punyah Building Materials Pvt Ltd, Faridabad vs. ITO Ward - 2(1), Faridabad

In the result, the appeals of the assesses are allowed

ITA 81/DEL/2021[2016-17]Status: DisposedITAT Delhi05 Sept 2024AY 2016-17

Section 131oSection 142(1)Section 143Section 143(2)Section 143(3)Section 251(1)Section 271(1)(c)Section 56(2)(viib)Section 68

Speedy Courier Services Pvt Ltd, Faridabad vs. ITO Ward - 2(4), Faridabad

In the result, the appeals of the assesses are allowed

ITA 80/DEL/2021[2016-17]Status: DisposedITAT Delhi05 Sept 2024AY 2016-17

Section 131oSection 142(1)Section 143Section 143(2)Section 143(3)Section 251(1)Section 271(1)(c)Section 56(2)(viib)Section 68

DCIT, Mumbai vs. Jaspalsingh Prehaladsingh Chandok, Mumbai

In the result, the appeal filed by the revenue is dismissed

ITA 4519/MUM/2023[2021-22]Status: DisposedITAT Mumbai03 Sept 2024AY 2021-22

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhailassessment Year 2021-22

For Appellant: Shri Mani JainFor Respondent: Shri Ankush Kapoor

Section 45Section 47Section 50B

Valuation Valuation Value INR Weight Value x Method approach weight Net asset Value Cost/Asset 289,74,08,285 2.00% 5,79,48,166 Method DCF method Income 58,40,12,022 49.00% 28,61,65,891 Earnings/Yield Market 27,40,53,187 49.00% 13,42,86,062 Method (Comparable Companies

Authorgen Technologies Pvt. Ltd., Mohali vs. ITO, Ward 6(1), Chandigarh

In the result, appeal of the assessee in ITA NO

ITA 212/CHANDI/2023[2015-16]Status: DisposedITAT Chandigarh02 Sept 2024AY 2015-16

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri K.M. Gupta, AdvocateFor Respondent: Shri J.S. Kahlon, CIT, DR &

Section 143(3)Section 263Section 56(2)Section 56(2)(viib)Section 68

facts and under the circumstances of the case and in law, the learned AO erred in rejecting the DCF method of valuation adopted by the appellant for valuing the shares and calculating the FMV on the basis of NAV model thereby making an addition of share premium ... viib) of the Income Tax Act, 1961 even when DCF method was allowable as per Rule 11UA(2)(b) and hence such an action is bad in law. 3. On the facts and under the circumstances of the case and in law, the learned AO erred in invoking Section

M/S Authorgen Technologies Pvt.Ltd, Mohali vs. Pr.CIT-1, Chandigarh

In the result, appeal of the assessee in ITA NO

ITA 171/CHANDI/2021[2015-16]Status: DisposedITAT Chandigarh02 Sept 2024AY 2015-16

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri K.M. Gupta, AdvocateFor Respondent: Shri J.S. Kahlon, CIT, DR &

Section 143(3)Section 263Section 56(2)Section 56(2)(viib)Section 68

S10 Healthcare Solutions Private Limited, Chennai vs. ITO, Corporate Ward-6(3), Chennai

In the result, appeal filed by the assessee is allowed

ITA 649/CHNY/2024[2014-15]Status: DisposedITAT Chennai21 Aug 2024AY 2014-15

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.649/Chny/2024 िनधा"रणवष"/Assessment Year: 2014-15 V. M/S.S10 Healthcare Solutions- The Ito, Pvt. Ltd., Corporate Ward-6(3), 102, Mahalingapuram Main Road, Chennai. Nungambakkam, Chennai-600 034. [Pan: Aagcp 7986 H] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Vijaya Sriram, CA &For Respondent: Shri P. Sajit Kumar, JCIT

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

assessee) has distorted the facts to arrive at a wrong conclusion. Further, the Ld.AR submitted that the AO had no power to change the DCF method chosen by the assessee and cited the following judicial decisions: (i) Vodafone M-Pesa Ltd Vs DCIT, Bombay High Court (ii) Karmic Labs ... Court (v) SB Industrial Engineering Vs ACIT, ITAT Chennai. (vi) Lalitha Jewelery Vs ACIT, ITAT, Chennai. 11. We note that the assessee has adopted DCF method for valuation of its shares as per Rule 11UA of the Income Tax Rules, 1962 (hereinafter in M/s.S10 Healthcare Solutions Pvt. Ltd. :: 9 :: short

ACIT-2(1)(1), Mumbai vs. Amalfi Realty Pvt. Ltd., Mumbai

ITA 888/MUM/2024[2015-16]Status: DisposedITAT Mumbai19 Aug 2024AY 2015-16

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Shri B R Baskaran, Hon’Ble

For Appellant: Shri Ajay Chandran (CIT-DR)For Respondent: Shri Mihir Naniwadekar

Section 143(3)Section 148Section 151Section 56(2)(viib)

guide on share valuation published by the ICAI provided three pre-requisites [viz. cash flow projections, discount rate and terminal value) for employing the DCF method for arriving at the fair market price of the share. The Assessing Officer noted that the cash flow projection 3 Amalfi Realty ... company, which necessarily have to be determined on the basis of its past performance, which is also a relevant fact while employing DCF method. The Assessing Officer found that these facts were not considered by the valuer. It was found that the valuer acted on the basis of the information

Mim Components Bangalore Private Limited, Bangalore vs. Income-Tax Officer, Ward-4(1)(3), Bangalore

In the result, the appeal filed by the assessee stand partly allowed for statistical purposes

ITA 683/BANG/2024[2016-17]Status: DisposedITAT Bangalore08 Aug 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2016-17

For Appellant: Shri A. Ravish Rao, CAFor Respondent: Smt. S. Praveena, CIT-DR

Section 142(1)Section 143(2)Section 143(3)Section 56(2)Section 56(2)(vii)

Rs.145/- per share. He submitted that M/s. Bharat Conductors Pvt. Ltd. paid Rs.7,25,00,000/- to the assessee which was valued at DCF method as per the valuation report dated 27.03.2016 prepared by one Shri D. Prasanna of M/s. D. Prasanna & Co. Bangalore. The Ld.AR vehemently argued that ... valuer had originally valued the equity share at Rs. 155 per share under the DCF method. However the assessee adopted Rs.145 per share. He submitted that the valuation was based on the adopted and having regard to the working of the competitor company namely Indo

Assistant Commissioner of Income Tax, Circle-1(1), New Delhi, C.R. Building vs. Addverb Technologies Pvt Ltd, New Delhi

In the result, the order of CIT(A) is upheld, and appeal of the Revenue is dismissed

ITA 3095/DEL/2023[2020-21]Status: DisposedITAT Delhi08 Aug 2024AY 2020-21

For Appellant: Ms. Neha Chaudhary, CIT-DRFor Respondent: Shri Ved Jain, Advocate, and Ms. Supriya Mehta, CA

Section 56(2)(viib)

with Face Value of Rs. 10/- per share at a premium of Rs. 4272.31 per share. The shares were valued following Discounted Cash Flow (DCF) method. The AO determined the value of share at Rs. 7426/- per share adopting Net Asset Value (NAV) method. He submitted that in the first ... face value of Rs. 10/- per share were issued at a premium of Rs. 4262.31. The assessee determined the market value of shares following DCF method as per Rule 11U and 11UA of the Income Tax Rules, 1962. The AO held that there is flaw in the method of valuation

Smart Information Worldwide Inc, Chennai vs. ACIT International Taxation 2(2), Chennai

The appeal stand allowed in terms of our above order

ITA 330/CHNY/2024[2016-17]Status: DisposedITAT Chennai06 Aug 2024AY 2016-17

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.330/Chny/2024 (िनधा9रणवष9 / Assessment Year: 2016-17) M/S. Smart Information Worldwide Inc. Dcit बनाम/ 49 Sixth Main Road, International Taxation -2(2) Vs. Raja Annamalaipuram, Chennai-600 028. Chennai-6. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaocs-8497-G (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओरसे/ Appellant By : Shri V. Ravichandran (Ca)- Ld.Ar " थ"कीओरसे/Respondent By : Shri Ar.V.Sreenivasan (Addl.Cit)-Ld. Sr. Dr सुनवाई की तारीख/Date Of Hearing : 20-06-2024 घोषणा की तारीख /Date Of Pronouncement : 06-08-2024

For Appellant: Shri V. Ravichandran (CA)- Ld.ARFor Respondent: Shri AR.V.Sreenivasan (Addl.CIT)-Ld. Sr. DR

Section 143(3)Section 195Section 48Section 50CSection 50D

assessee had submitted valuation report for shares sold during that year. The said valuation report was based on Discounted Cash Flow (DCF) Method and the value per share was arrived at Rs.2135/- per share. Accordingly, Ld. AO proceeded to adopt the said valuation to compute the capital gains ... gets attracted in the case of the assessee. Rule 11UA provide for valuation of shares under two methods namely Net Asst Method (NAV) and DCF Method. The values arrived by DCF method was Rs.2135 per shares whereas value as per NAV method was Rs.31.41 per share. The option would

Pathfinder Publishing Private Limited, Hyderabad vs. ACIT., Circle -16(2), Hyderabad

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

ITA 39/HYD/2024[2017-18]Status: DisposedITAT Hyderabad31 Jul 2024AY 2017-18

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri S.K. Gupta, AdvocateFor Respondent: : Ms. TH Vijaya Lakshmi, CIT-DR

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

Rs.10/- per share at a premium of Rs.460/- per share. As regards the valuation of shares the assessee opted for discounted free cash flow (“DCF”) method mentioned under rule 11UA(2)(b) of the income tax Rules,1962 (“the Rules”). However, the Ld. AO changed the method of valuation ... examined with reference to the provisions of Section 56(2)(viib) of the Act. In the instant case, the assessee has opted for the DCF method and produced the certificate of a CA i.e. GN & Associateswherein the value of the share is determined at Rs.463.10/- per share. The contention

Multiventure Estates Pvt Ltd, Mumbai vs. Income Tax Officer, Ward 10(2)(4), Mumbai

ITA 510/MUM/2024[2008-09]Status: DisposedITAT Mumbai31 Jul 2024AY 2008-09

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawal

Section 133(6)Section 143(3)Section 68

bank statement of the Vinamra Universal traders Pvt. Ltd g) Valuation report issued by Chartered Accountant under Income Tax Rule 11BB/Section 56(viib). Under DCF Method. h) Copy of Share Application form (i) Copy of Board resolution and letter of offer for Investment in the company issued by the appellant ... funds. The amount of share premium was justified by way of filing of valuation report of a Chartered Accountant in which Discounted Cash Flow (DCF) method was followed. The relevant extract from the said order in para 5 is reproduced as under: “5. We have heard rival submission

DCIT-CC-5(3), Mumabi, Mumbai vs. Jwl Cold Store Private Limited, Panvel, Maharashtra

In the result, appeal of the revenue is dismissed

ITA 3098/MUM/2023[2014-15]Status: DisposedITAT Mumbai31 Jul 2024AY 2014-15

Bench: Shri Pavan Kumar Gadale, Hon’Ble & Shri Girish Agrawal, Hon’Ble

For Appellant: Shri Satish Mody, A/RFor Respondent: Ms. Rajeshwari Menon, Sr. D/R

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

arrived at a conclusion that assessee is deviating from its own stand and submitting valuation reports multiple times with different results. He thus, rejected DCF method adopted by assessee and concluded to take NAV as the correct method to determine the fair market value of shares issued by assessee ... taken by assessee, same cannot be withdrawn or taken away by ld. AO by adopting a different method of valuation. Assessee had selected DCF method and shares issued were valued from Registered valuer who adopted projections of sales and expenditure and various assumptions and scenarios which were furnished

Income Tax Officer, Delhi vs. Toshiba Corporation, Gurgoan, Haryana

In the result, appeal of the Revenue is dismissed, being devoid of any merit

ITA 2532/DEL/2023[2016-17]Status: DisposedITAT Delhi26 Jul 2024AY 2016-17

Bench: Shri Vikas Awasthy & Shri Naveen Chandraआअसं.2532/िद"ी/2023 (िन.व. 2016-17) Income Tax Officer, International Taxation Ward-3(1)(1), ...... अपीलाथ"/Appellant Delhi 110002

For Appellant: Shri Vijay B Vasanta, CIT-DRFor Respondent: S/Shri Deepak Chopra, and Ankul Goyal, Advocates

Section 201Section 201(1)

long term capital gain arising in the hands of the sellers of the shares without appreciating the fact that valuation of shares by applying DCF method based on the premise of going concern of the company whose shares have been transacted in this case i.e. UEM India ... long term capital gain arising in the hands of the sellers of the shares without appreciating the fact that valuation report for application of DCF method to arrive at fair price of shares had adopted several variables such as return on cost of capital, projected revenue in future years, projected