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“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

Invesco(India) Private Limited, Hyderabad vs. DCIT, Circle -2 (1), Hyderabad

In the result, appeal of the Assessee is partly allowed for statistical purposes

ITA 111/HYD/2022[2017-18]Status: DisposedITAT Hyderabad30 Jun 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA, Sriram SeshadriFor Respondent: Shri B Bala Krishna, CIT-DR
Section 143(3)Section 144C(5)

Flow [in short “DCF”] method. However, when it comes to accounting treatment for amalgamation of two companies, it is Net Asset Value [in short “NAV”] method. Therefore, the observation of the Assessing Officer in light of valuation reports that, the assessee has designed tax evasion plan with the creation ... Rs.81,635/- as on the date of acquisition. Although, the assessee claims that it has followed DCF method for purchase of shares and NAV method for recording asset and liabilities for the purpose of amalgamation, but, there cannot be two enterprise value for any entity on the very same

Triveni Knits Private Limited, Ludhiana vs. ITO Ward 1 (3), Ludhiana

ITA 246/CHANDI/2024[2013-14]Status: DisposedITAT Chandigarh09 Jun 2025AY 2013-14

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Shri Rajesh Mehru, CA and Shri Dev Mehru, CAFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR
Section 56(2)(vib)Section 56(2)(viib)Section 69

valuation using the DCF method is permitted under Rule 11UA and is more appropriate in case of a newly incorporated company where asset-based NAV method may not reflect the true value. Ld. CIT(A) called for the remand report from Assessing Officer. 8. In accordance with Rule ... assessee on the Discounted Cash Flow (DCF) method of valuation. However, the valuation was rejected by the AO, and the Net Asset Value (NAV) method under Rule 11UA(2)(a) was applied instead. The said rejection and consequent addition were upheld by the Tribunal. 12. We found that no valuation

Madhurima International Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 3(2)(1), Mumbai

ITA 4430/MUM/2024[2013-14]Status: DisposedITAT Mumbai06 May 2025AY 2013-14

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SMT. RENU JAUHRI (Accountant Member)

For Appellant: Shri Madhur AgrawalFor Respondent: Shri R. R. Makwana
Section 143(3)Section 263Section 56(2)(viib)

independent valuer using Discounted Cash Flow (DCF) Method 3 Assessment Year: 2013-2014 adopted by the Assessee and used Net Asset Value (NAV) Method to determine the Fair Market Value of the Shares at INR.115 per Share invoking the provisions contained in Rule 11UA of the Income Tax Rule ... INR.135/-) being aggregate payment received by the Assessee in excess of the Fair Market Value determined by the Assessing Officer using NAV Method. 6. Being aggrieved the Assessee preferred appeal before the CIT(A) challenging the above addition made by the Assessing Officer under Section 56(2)(viib

Anatole Solutions Private Limited, Jaipur vs. ACIT Circle 2, Jaipur

In the result, the appeal of the assessee is allowed

ITA 1082/JPR/2024[2017-18]Status: DisposedITAT Jaipur28 Apr 2025AY 2017-18
For Appellant: Shri Ashok Kumar Gupta, AdvocateFor Respondent: Shri Manoj Kumar, JCIT-DR
Section 115BSection 234ASection 56(2)(viib)

firm of Chartered Accountants, submitted before him and the AO determined the Fair Market Value (“FMV”) of the shares by applying Net Asset Value (“NAV”) method and disregarded the DCF method as originally adopted by the assessee company as per law and allowable. The AO calculated the value per share ... Rs.11.15, considering the NAV method. Accordingly, the AO was of the view that the amount as received by the assessee company from resident investors over and above the NAV of Rs.11.15 as calculated by him during the course of assessment proceedings should be added to the income of the assessee

M/S Accord Mediplus Pvt Ltd, Pune vs. Income Tax Officer, Ward-1(1), Pune

ITA 17/PUN/2024[2018-19]Status: DisposedITAT Pune07 Apr 2025AY 2018-19

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Kishor B. Phadke and Shri Piyush BafnaFor Respondent: Shri Chandra Vijay
Section 1Section 147Section 56(2)

Appeal has erred in law and on facts, in upholding the illegal actions of Ld. AO in disregarding DCF method and thrusting NAV method, to compute the FMV of shares issued by the Appellant from time to time; and thereby, working out extra share premium and holding the same ... with the AO and hence, Ld. AO as well as Ld. CIT-Appeal has erred in computing the FMV by applying the NAV method. 11. On the facts and in the circumstances of the case, Ld. CIT- Appeal has erred in law and on facts, in not referring the matter

M/S Accord Mediplus Pvt Ltd, Pune vs. Income Tax Officer, Ward-1(1), Pune

ITA 16/PUN/2024[2017-18]Status: DisposedITAT Pune07 Apr 2025AY 2017-18

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.13 To 17/Pun/2024

Section 1Section 147Section 56(2)

Appeal has erred in law and on facts, in upholding the illegal actions of Ld. AO in disregarding DCF method and thrusting NAV method, to compute the FMV of shares issued by the Appellant from time to time; and thereby, working out extra share premium and holding the same ... with the AO and hence, Ld. AO as well as Ld. CIT-Appeal has erred in computing the FMV by applying the NAV method. 11. On the facts and in the circumstances of the case, Ld. CIT- Appeal has erred in law and on facts, in not referring the matter

M/S Accord Mediplus Pvt Ltd, Pune vs. Income Tax Officer, Ward-1(1), Pune

ITA 15/PUN/2024[2016-17]Status: DisposedITAT Pune07 Apr 2025AY 2016-17

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Kishor B. Phadke and Shri Piyush BafnaFor Respondent: Shri Chandra Vijay
Section 1Section 147Section 56(2)

Appeal has erred in law and on facts, in upholding the illegal actions of Ld. AO in disregarding DCF method and thrusting NAV method, to compute the FMV of shares issued by the Appellant from time to time; and thereby, working out extra share premium and holding the same ... with the AO and hence, Ld. AO as well as Ld. CIT-Appeal has erred in computing the FMV by applying the NAV method. 11. On the facts and in the circumstances of the case, Ld. CIT- Appeal has erred in law and on facts, in not referring the matter

M/S Accord Mediplus Pvt Ltd, Pune vs. Income Tax Officer, Ward-1(1), Pune

ITA 14/PUN/2024[2015-16]Status: DisposedITAT Pune07 Apr 2025AY 2015-16

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Kishor B. Phadke and Shri Piyush BafnaFor Respondent: Shri Chandra Vijay
Section 1Section 147Section 56(2)

Appeal has erred in law and on facts, in upholding the illegal actions of Ld. AO in disregarding DCF method and thrusting NAV method, to compute the FMV of shares issued by the Appellant from time to time; and thereby, working out extra share premium and holding the same ... with the AO and hence, Ld. AO as well as Ld. CIT-Appeal has erred in computing the FMV by applying the NAV method. 11. On the facts and in the circumstances of the case, Ld. CIT- Appeal has erred in law and on facts, in not referring the matter

M/S Accord Mediplus Pvt Ltd, Pune vs. Income Tax Officer, Ward-1(1), Pune

ITA 13/PUN/2024[2014-15]Status: DisposedITAT Pune07 Apr 2025AY 2014-15

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Kishor B. Phadke and Shri Piyush BafnaFor Respondent: Shri Chandra Vijay
Section 1Section 147Section 56(2)

Appeal has erred in law and on facts, in upholding the illegal actions of Ld. AO in disregarding DCF method and thrusting NAV method, to compute the FMV of shares issued by the Appellant from time to time; and thereby, working out extra share premium and holding the same ... with the AO and hence, Ld. AO as well as Ld. CIT-Appeal has erred in computing the FMV by applying the NAV method. 11. On the facts and in the circumstances of the case, Ld. CIT- Appeal has erred in law and on facts, in not referring the matter

Tajshree Autowheels Private Limited, Nagpur vs. ACIT Circle-4, Nagpur

In the result, assessee’s appeal is allowed for statistical purposes

ITA 400/NAG/2024[2014-15]Status: DisposedITAT Nagpur04 Mar 2025AY 2014-15

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Madhav VichoreFor Respondent: Shri Abhay Y. Marathe
Section 56(2)Section 56(2)(viib)

shares: Rule 11UA(2) of the Income Tax Rules outlines the methodologies for fair valuation. For unlisted equity shares, there are two options: (i) NAV method: This method involves valuing equity based on the net asset value, considering the company’s book value of assets and liabilities

Karthick Chilaka, Chennai vs. ITO, International Taxation Ward-1(1), Chennai

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

ITA 947/CHNY/2023[2014-15]Status: DisposedITAT Chennai28 Feb 2025AY 2014-15

Bench: Shri George George K, Hon’Ble & Shri S.R. Raghunatha, Hon’Ble

Section 263Section 28

No.947/Chny/2023 8. The ClIT(Appeals) - 16 failed to appreciate that the determination of fair market value by the JAO by following the method of NAV method, which is nothing but book value was incorrect and suffered from multiple errors thereby vitiating the addition made in terms of section

Nepra Environmental Solutins Private Limited, Gandhinagar vs. The Income Tax Officer, Ward-3(1)(1), Ahmedabad

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

ITA 1683/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad25 Feb 2025AY 2013-14

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं/Ita No.1683/Ahd/2024 निर्धारण वर्ष / Assessment Year : 2013-14 | Nepra Environmental- Solutions Private Limited 705, Sharan Circle Hub Nr. Sharan Homes, Zundal Gandhinagar 382 421 (Gujarat) स्थायी लेखा सं./Pan: Aaccp 0273 F (अपीलार्थी/ Appellant) Assessee By: Revenue By: | The Income Tax Officer बनाम / | Ward-3(1)(1) V/S. Ahmedabad (प्रत्यर्थी / Respondent) Shri Divyakant Parikh, Ar Shri Santosh Kumar, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 20/02/2025 25/02/2025 घोषणा की तारीख / Date Of Pronouncement: आदेश/Order Per Makarand V. Mahadeokar, Am: This Appeal Has Been Preferred By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi [Hereinafter Referred To As “Cit(A)"], Dated 07-08-2024, For The

For Appellant: Revenue byFor Respondent: The Income Tax Officer
Section 131Section 143(3)Section 56(2)(viib)Section 68

assessee's income. Additionally, the AO rejected the DCF method of share valuation adopted by the assessee and applied the NAV method, leading to an alternative addition of Rs.70,99,350/- under section 56(2)(viib) of the Act. The AO also disallowed Rs.1,97,068/- claimed as expenses, stating ... adopted by the assessee as per Rule 11UA(2) of the Income Tax Rules, 1962. The AO replaced it with the Net Asset Value (NAV) method without providing a valid reason. This action is contrary to the legal principle that the choice of valuation method under Rule 11UA(2) lies

Gateway Office Parks Priovate Limitedi, Chennai vs. ACIT, Corporate Cicle-6(1), Chennai

ITA 617/CHNY/2023[2015-16]Status: DisposedITAT Chennai19 Feb 2025AY 2015-16

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.617/Chny/2023 निर्धारण वर्ष /Assessment Years: 2015-16 Gateway Office Parks Private Limited, Block No.A6, Ground Floor, No.16, Gst Road, Perungalathur, Chennai-600 063. [Pan: Aajcs8198P] (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By प्रत्यर्थी की ओर से /Revenue By सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख /Date Of Pronouncement Asst. Commissioner Of Income Tax, Corporate Circle-6(1), Chennai. (प्रत्यर्थी/Respondent) Shri S.Ananthan, Advocate (Virtual). Shri Nilay Baran Som, Cit 22.01.2025 19.02.2025 आदेश / Order Per Amitabh Shukla, A.M : This Appeal Is Filed By The Assessee Against The Order Bearing Din & Order No.Itba/Apl/M/250/2022-23/1050825008(1) Dated 16.03.2023 For The Assessment Years 2015-16. Through The Aforesaid Appeal The Assesse Has Challenged Order U/S 250 Dated 16.03.2023 Passed By Cit(A), Chennai. 2.0 Ground Of Appeal No.1 Has Been Found To Be General In Nature & Hence Not Worthy Of Any Meritorious Adjudication.

Section 250Section 56(2)(viib)

method and applied ratio Page - 1 - of 14 Page - 2 - of 14 ITA No.617/Chny/2024 laid down in Rule 11UA(2) viz-a-viz the NAV method. The addition of Rs.11,67,14,298/- was seminal to said assumptions of the Ld. AO. 3.1 The Ld. Counsel for the assessee submitted

Assistant Commissioner of Income Tax Circle 6 1 1, Mumbai vs. Dlk Commercial Private Limited, Mumbai

In the result, the appeal of the Revenue is allowed

ITA 864/MUM/2024[2014-15]Status: DisposedITAT Mumbai10 Feb 2025AY 2014-15

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri B.R. Baskaranassessment Year : 2014-15

For Appellant: Shri Satish ModiFor Respondent: Smt. Sanyogita Nagpal, CIT-DR
Section 56(2)(via)Section 56(2)(viia)

Butala & Desai, the price of shares was determined at Rs. 60/- per share. However, the said report was prepared by combining Net Asset Value (NAV) method and Average income method. In another report dt. 30-06-2016 prepared by M/s. Ambavat Jain & Associate LLP, the value of shares was determined ... share. However, this report was also prepared by combining NAV method and DCF method. In the third report, the statutory auditors had given NIL value to the shares as per DCF method. 2.2. The AO rejected all the three reports, since they were not prepared as per the methods prescribed

Dreams Dwellers LLP(As Legal Representative of Megacorp Developers Pvt Ltd, Mumbai vs. ACIT -24(1) (Earlier ACIT Cir 10(1)(1), Mumbai)

In the result, the appeal of the assessee is allowed

ITA 4937/MUM/2024[2014-15]Status: DisposedITAT Mumbai30 Jan 2025AY 2014-15

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh () Assessment Year: 2014-15 Dreams Dwellers Llp (As Legal Acit-24(1) (Earlier Acit Cir 10(1)(1) Representative Of Megacorp Mumbai), Vs. Developers Pvt. Ltd., Mumbai) Room No. 604, 6Th Floor, Piramal 702, Natraj, Mv Road, Junction W E Chambers Parel, Highway, Andheri (E), Mumbai-400012. Mumbai-400069. Pan No. Aafcm 0366 B Appellant Respondent

For Appellant: Mr. Ajay SinghFor Respondent: Ms. Sanyogita Nagpal, CIT-DR
Section 143(1)Section 143(3)Section 56(2)(viib)

petitioner. This, even after he the primary grievance of the petitioner. This, even after he concedes with the method of valuation namely, NAV Method or concedes with the method of valuation namely, NAV Method or concedes with the method of valuation namely, NAV Method or the DCF Method to determine ... invoking Net Asset Value (NAV) has valued the share premium invoking Net Asset Value (NAV) has valued the share premium invoking Net Asset Value (NAV) method substituting the dividend di method substituting the dividend discounting method applied by scounting method applied by the independent valuer. N the independent valuer

M/S Unihealth Consultancy Limited, Mumbai vs. DCIT, 8 (3) (1), Mumbai

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

ITA 4387/MUM/2024[2017-18]Status: DisposedITAT Mumbai29 Jan 2025AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2017-18 M/S Unihealth Consultancy Ltd., The Dy. Cit-8(3)(1), H-13 & H-14 Everest, 9Th Floor, Room No. 615, 6Th Floor, Aayakar Vs. Tardeo Road, Bhavan, Maharishi Karve Road, Mumbai-400034. Mumbai-400020. Pan No. Aabcu 1551 C Appellant Respondent

For Appellant: Ms. Rajeshwari Menon, Sr. DRFor Respondent: Mr. Rajesh Kalyani/ Ajay Dhoot
Section 143(3)Section 68

himself valued the share on sessee and himself valued the share on the basis of net asset value the basis of net asset value (NAV) method at Rs.13.44 per share. method at Rs.13.44 per share. Accordingly, held the held the balance excess amount of the share premium balance excess amount ... available with the assessee to adopt, either the DC Method or available with the assessee to adopt, either the DC Method or the NAV Method, for valuation of Market V the NAV Method, for valuation of Market Value of shares, at alue of shares, at their own choice. Moreover

Holiday Triangle Travel Private Limited, Gurgaon vs. Income Tax Officer, Jaipur

In the result, appeal of the assessee is allowed

ITA 67/JPR/2024[2014-15]Status: DisposedITAT Jaipur20 Jan 2025AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri Dilip Shivpuri, Advocate &For Respondent: Shri Gautam Singh Choudhary, JCIT
Section 142(1)Section 143(2)Section 250Section 56(2)(viib)

have obtained the fresh valuation report from independent valuer after recording reasons instead of arbitrarily changing the method of valuation to Net Asset Value (NAV) method. 3 Holiday Triangle Travel Pvt. Ltd., Gurgaon. The above grounds of appeal are mutually exclusive and without prejudice to each other. The Appellant craves ... matter of valuation of unquoted equity shares, has been completely left to the discretion of the assessee. It is his option whether to choose NAV Method (Book Value) under clause (a) or to choose DCF Method under clause (b) and the AO cannot adopt a method of his own choice

Patel Minerals Pvt. Ltd., Udaipur vs. ACIT, Circle-1, Udaipur

In the result, the appeal of the assessee is allowed

ITA 22/JODH/2024[2015-16]Status: DisposedITAT Jodhpur02 Jan 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI, J (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

Section 142Section 143(2)Section 143(3)Section 56Section 56(2)(viib)

matter of valuation of unquoted equity shares, has been completely left to the discretion of the assessee. It is his option whether to choose NAV Method (Book Value) under clause (a) or to choose DCF Method under clause (b) and the ld. AO cannot adopt a method ... matter of valuation of unquoted equity shares, has been completely left to the discretion of the assessee. It is his option whether to choose NAV Method (Book Value) under clause (a) or to choose DCF Method under clause (b) and the ld. AO cannot adopt a method

Autope Payment Solutions Private Limited, Ghaziabad vs. ACIT, Circle-2(2), Delhi

In the result, ground nos

ITA 86/DEL/2023[2017-18]Status: DisposedITAT Delhi20 Dec 2024AY 2017-18

Bench: Shri Mahavir Singh & Shri S. Rifaur Rahmanassessment Year : 2017-18

For Appellant: Shri Akhilesh Kumar, Adv.; &For Respondent: Shri Yogesh Kumar Nayyar, Sr. DR
Section 142(1)Section 143(2)Section 143(3)Section 56(2)

According to him, it is on higher side. After rejecting the method of DCF adopted by the assessee he proceeded to calculate NAV method i.e. other method provided in rule 11UA of the Rules and he determined the fair market value of unquoted shares of the assessee ... prescribed methodology. The Appellant-Revenue had the option to conduct its own 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

Assistant Commissioner of Income Tax, Hyderabad vs. Mytrah Vayu (Gujarat) Private Limited, Hyderabad

In the result, the appeal ofthe Revenue is dismissed

ITA 172/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad18 Dec 2024AY 2015-16

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

For Appellant: Shri P S Choudhary, CIT. DRFor Respondent: Date of Hearing
Section 56(2)Section 56(2)(viib)

supplied by the assessee to the merchant banker was not verified, the AO had rightly rejected the DCF method and adopted net asset value (NAV) method to determine the FMV of shares. 6. Per contra, Shri Ravi Bharadwaj, Ld. AR appearing for the assessee submitted that as per provision ... Rule 11UA of the IT Rules, an option was available with the assessee to adopt either DCF method or NAV method for valuation of its shares. Therefore, it was not open for the AO to reject the DCF method of valuation as adopted by the assessee. He further submitted that