← All Phrases

“NAV method”

Special Rate ProvisionsRule 11UARule 11UA182 judgments

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

Leading authorities on NAV 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 NAV method

Techpark Hotels Pvt Ltd, Gurgaon vs. Addi. CIT Special Range-9, New Delhi

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

ITA 9450/DEL/2019[2015-16]Status: DisposedITAT Delhi20 Mar 2026AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumartechpark Hotels Pvt. Ltd., Addl. Cit, Ground Floor, Central Wing, Special Range-9, Thapar House 124, Janpath, Vs. New Delhi. New Delhi-110001. Pan-Aabce5833H (Appellant) (Respondent) Assessee By Shri Neeraj Jain, Adv. & Shri Tavish Verma, Adv. Ms. Harpreet Kaur Hansra Sr. Dr Department By Date Of Hearing 20.01.2026 Date Of Pronouncement 20.03.2026 O R D E R Per Vimal Kumar, Jm: The Appeal Filed By The Assessee Is Against Order Dated 11.09.2019 Of The Learned Commissioner Of Income Tax (Appeals), New Delhi [Hereinafter Referred To As ‘The Ld. Cit(A)’] Passed U/S 250 Of The Income Tax Act, 1961, [Hereinafter Referred To As ‘The Act’] Arising Out Of Assessment Order Dated 30.12.2017 Of The Ld. Assessing Officer U/S 143(3) Of The Act For Assessment Year 2015-16. 2. Brief Facts Of The Case Are That The Assessee Filed Return Declaring Loss Of Rs.23,06,28,106/- On 30.11.2015. Notice U/S 143(2) Dated 22.09.2016 Was Issued. Notices U/S 142(1) Were Issued. Sh. Nikhil Agarwal & Shri Nirmal Malpani, Ca Appeared & Filed Details. On Completion Of Proceedings, Ld. Ao Vide Order Dated Techpark Hotels Pvt. Ltd. Vs. Acit

Section 142(1)Section 143(2)Section 143(3)Section 154Section 234DSection 250Section 56(2)Section 56(2)(viib)

facts and in law in rejecting the Discounted Cash Flow ['DCF'] method for valuation of shares and in considering the Net Asset Value ['NAV'] method without appreciating that the FMV of the shares was computed keeping in view the future growth of the enterprise and was certified by a Chartered ... variation was a result of certain unforeseen factors. 7. That the CTT(A) erred on facts and in law in failing to appreciate that NAV method cannot be taken as the price at which transaction would take place in case of going concern and moreover, valuation of share

Navkar Wollens Private Limited, Bikaner vs. ACIT Circle-3, Bikaner

In the result, the appeal of the assessee is allowed

ITA 670/JODH/2025[2014-15]Status: DisposedITAT Jodhpur26 Feb 2026AY 2014-15

Bench: Dr. Mitha Lal Meena, Hon’Ble & Shri Sudhir Pareek, Hon’Blenavkar Woollens Private Ltd. Assistant Commissioner Of Rani Bazar, Bikaner, H.O. Income Tax, Circle – 3 Bikaner, Bikaner Bikaner - 334001 Pan No. Aabcn 9287 G Assessee By Shri Rajendra Jain, Advocate & Smt. Raksha Birla, Ca (Physical) Revenue By Smt. Runi Pal, Cit-Dr & Shri Lalit Kumar Bishnoi, Addl. Cit-Dr (Virtual) Date Of Hearing 29.01.2026. Date Of Pronouncement 26.02.2026. Order Dr. Mitha Lal Meena, A.M.: This Appeal Is Filed By Assessee Against The Order Of National Faceless Appeal Centre Delhi [Hereinafter Referred To As Nfac/Cit(A)] Dated 30.07.2025 With Respect To Assessment Year 2014-15 Challenging Therein Sustaining The Addition Of Rs. 2,34,04,480/- On Account Of Difference Between The Fair Market Value & The Issue Price Of The Equity Shares By Questioning The Method Of Valuation.

Section 144Section 147Section 56(2)(viib)

Hotels Pvt. Ltd. (supra), the Hon’ble Madras High Court has observed that the AO was not justified in adopting NAV method and making addition u/s 56(2)(viib) when the assessee company has used the privilege of choosing the DCF method for arriving at the value of shares instead ... NAV method. In conclusion, the Hon’ble Court has observed that AO was not justified in adopting NAV method and making addition u/s 56(2)(viib) when the assessee submitted that value of shares were done by adopting a discounted free cash flow (DSF Method) as per the report

Karadi Path Education Company Private Limited, Chennai vs. Commissioner, Chennai

ITA 1848/CHNY/2025[2018-2019]Status: DisposedITAT Chennai17 Feb 2026AY 2018-2019

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1848/Chny/2025 निर्धारण वर्ष / Assessment Year: 2018-19 Karadi Path Education Company Private Limited, 3A No.11, Dev Regency, I Main Road, Gandhi Nagar, Adyar, Chennai - 600 020. [Pan: Aaeck-2995-D] (अपीलार्थी/Appellant) Dcit, Vs. Corporate Circle -4(1), Chennai. (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By : Shri. Pradhan Priya Dass, C.A. (By Virtual) प्रत्यर्थी की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/Date Of Hearing : 27.11.2025 घोषणा की तारीख/Date Of Pronouncement : 17.02.2026 आदेश /O R Der Per S. R. Raghunatha, Am: This Appeal By The Assessee Is Filed Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, (In Short “Ld.Cit(A)”) For The Assessment Year 2018-19, Dated 29.04.2025 In Respect Of The Order Of The National E-Assessment Centre, Delhi (In Short 'Ao') Passed U/S.143(3) Of The Income Tax Act, 1961 ( In Short ‘The Act') Dated 28.04.2021. :-2-:

For Appellant: Shri. Pradhan Priya Dass, C.A. (by Virtual)For Respondent: Ms. Gouthami Manivasagam, JCIT
Section 143(3)Section 56(2)(vii)Section 56(2)(viib)

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

K. G. Finvest Private Limited, East Delhi vs. Central Circle 29, Delhi, New Delhi

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

ITA 4330/DEL/2025[2015-16]Status: DisposedITAT Delhi29 Jan 2026AY 2015-16

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2015-16] K.G. Finvest Pvt. Ltd. Vs Central Circle-29, F-24 F/Floor, I.Sc Pankaj Delhi Central Market, Mandawali Fazalpur, Nr Natraj Vihar Society, I.P. Extn., New Delhi- 110092. Pan-Aaack4032H Appellant Respondent Appellant By Shri Sudesh Garg, Adv. & Shri Prince Bansal, Ca Respondent By Shri Jitender Singh, Cit Dr Date Of Hearing 26.11.2025 Date Of Pronouncement 29 .01.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 17.06.2025 Passed By Ld. Commissioner Of Income Tax (A)-30, New Delhi [“Ld. Cit(A)”] In Appeal No. Cit(A), Delhi-5/10256/2017-18 U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 29.12.2017 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2015-16. 2. Brief Facts Of The Case Are That Assessee Company Has Filed Its Return Of Income On 28.09.2015, Declaring Total Income Of Inr 5,09,130/-. The Case Was Selected Under Limited Scrutiny & Notice U/S 143(2) Followed By Statutory Notices Issued U/S 142(1) Were Issued From Time To Time. In Response, Assessee Filed Submissions & Relevant Details Alongwith Evidences. The Ao Observed That The Assessee Issued 8,40,000 Equity Shares Of Inr 10/- Each At A Premium Of Inr 490/- Each & The Valuation Of Shares Was Done By Following Dcf Method. However, The Ao Rejected The Method Of Valuation Of Share Adopted By The Assessee & Re-Computed The Value Per Share At Inr 50.35 Per Share As Per Nav Method & Made Addition Of Differential Amount Of Inr 37,77,06,000/- U/S 56(2)(Viib) Of The Act.

Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153CSection 250Section 56(2)Section 56(2)(viib)

method of valuation of share adopted by the assessee and re-computed the value per share at INR 50.35 per share as per NAV method and made addition of differential amount of INR 37,77,06,000/- u/s 56(2)(viib) of the Act. 3. Against the said order, assessee ... Income Tax Rules, 1962 (“the Rules”) where two methods are prescribed for valuation of unquoted equity shares namely, (i) Net Asset Value Mehtod (NAV method) & (ii) Discounted Free cash Flow Method (DCF method). The assessee has opted for DCF method for valuation of its share as provided in clause

DCIT Central Circle 7 1 Mumbai, Mumbai vs. Soyumm Marketing Private Limited, Mumbai

In the result, the appeal of the Revenue, being ITA no

ITA 4306/MUM/2024[2017-18]Status: DisposedITAT Mumbai04 Dec 2025AY 2017-18

Bench: Shri Sandeep Singh Karhailshri Prabhash Shankardeputy Commissioner Of Income Tax, Central Circle - 7(1) Room No.653, Aaykar Bhawan, Churchgate, ............... Appellant Mumbai - 400020 V/S Spectra Realities Private Limited, 9, Floor-I, Plot – 51, Kapadia Chamber, Devji Ratansi Marg, ……………… Respondent Chinchbunder, Mumbai – 400009 Pan: Aalcs7233B Deputy Commissioner Of Income Tax, Central Circle - 7(1) Room No.653, Aaykar Bhawan, Churchgate, ............... Appellant Mumbai - 400020

For Appellant: Shri Bhupendra ShahFor Respondent: Shri Swapnil Choudhary, Sr.AR
Section 142(1)Section 143(2)Section 143(3)Section 250Section 56(2)(viib)

that the Discounted Cash Flow (“DCF”) of the assessee company is not available, proceeded to undertake the valuation as per the Net Asset Value (“NAV”) method adopted by the two Chartered Accountants in the valuation report furnished by the assessee. Further, noting certain inconsistencies in the valuation report submitted ... Lukkad and Associates and Charted Accountant Rupali ITAs No.4304 & 4306/Mum/2024 (A.Ys. 2017-18) 6 Chandak & Company. They have done the valuation as per the NAV method. The A.O also accepted that, the Net Asset Value (NAV) method adopted by the valuer is appropriate in the facts of the case

DCIT Central Circle 7 1 Mumbai, Mumbai vs. Spectra Realties Private Limited, Mumbai

In the result, the appeal of the Revenue, being ITA no

ITA 4304/MUM/2024[2017-18]Status: DisposedITAT Mumbai04 Dec 2025AY 2017-18

Bench: Shri Sandeep Singh Karhailshri Prabhash Shankardeputy Commissioner Of Income Tax, Central Circle - 7(1) Room No.653, Aaykar Bhawan, Churchgate, ............... Appellant Mumbai - 400020 V/S Spectra Realities Private Limited, 9, Floor-I, Plot – 51, Kapadia Chamber, Devji Ratansi Marg, ……………… Respondent Chinchbunder, Mumbai – 400009 Pan: Aalcs7233B Deputy Commissioner Of Income Tax, Central Circle - 7(1) Room No.653, Aaykar Bhawan, Churchgate, ............... Appellant Mumbai - 400020

For Appellant: Shri Bhupendra ShahFor Respondent: Shri Swapnil Choudhary, Sr.AR
Section 142(1)Section 143(2)Section 143(3)Section 250Section 56(2)(viib)

that the Discounted Cash Flow (“DCF”) of the assessee company is not available, proceeded to undertake the valuation as per the Net Asset Value (“NAV”) method adopted by the two Chartered Accountants in the valuation report furnished by the assessee. Further, noting certain inconsistencies in the valuation report submitted ... Lukkad and Associates and Charted Accountant Rupali ITAs No.4304 & 4306/Mum/2024 (A.Ys. 2017-18) 6 Chandak & Company. They have done the valuation as per the NAV method. The A.O also accepted that, the Net Asset Value (NAV) method adopted by the valuer is appropriate in the facts of the case

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

provides that the FMV of unquoted shares for the purpose of Section 56(2)(viia) shall be determined using the "Net Asset Value" (‘NAV’) method. • However, the learned AO, to the contrary has adopted a valuation made as per DCF method and erroneously concluded that the FMV of the shares ... accordance with the valuation methodology prescribed under the Act. • If one were to compute the FMV of the shares bought back under the NAV method as prescribed under Rule 11UA, it works out to INR 68.48 per share and the consideration paid by the Company is considerably higher than