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of ITAT held the assessee failed to justify share valuation under Sec. 56(2)(viib), as the submitted valuation report omitted loan liabilities. CIT(A)'s direction for valuation from two valuers at assessee's option while restricting AO's scope was deemed unjustified. The DCF-based valuation was questioned due to lack of business activities in subsequent years. Following precedent from Madras HC, ITAT remanded the matter back to AO for fresh determination of share FMV, as the original fact-finding exercise was incomplete. The valuation must consider all liabilities and actual business performance. Appeal allowed for statistical purposes, directing AO to conduct comprehensive share valuation under Sec. 56(2)(viib).
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