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of Revision u/s 263 - issue of shares at a premium - As in present case, the valuation made by the assessee is not in accordance with Rule 11UA , as assessee tried to increase the valuation by inclusion of share application money in net worth or consequently not increasing the total issued capital. Thus, it did not satisfy Clause (i) of above explanation. Further clause (ii) was not at all looked by AO with respect to other valuation, so there is no question of reaching at any satisfaction by LD AO. - ld PCIT has correctly held that order passed u/s 143 (3) of The Act by the ld AO is erroneous so far as prejudicial to the interest of revenue - AT
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