Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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ITAT held that the assessee, a company director, was not liable for additional tax assessment on share premium. The tribunal rejected revenue's attempt to reassess share valuation, finding no procedural default in the original merchant banker's valuation. The shares issued at Rs. 12,628.20 per unit were deemed appropriately valued under prescribed rules. The tribunal specifically noted that different valuation methodologies cannot be arbitrarily applied when an initial valuation has been correctly determined. Consequently, the revenue's appeal was comprehensively dismissed, upholding the original assessment and protecting the assessee from supplementary tax liability on share issuance.
ITAT held that the assessee, a company director, was not liable for additional tax assessment on share premium. The tribunal rejected revenue's attempt to reassess share valuation, finding no procedural default in the original merchant banker's valuation. The shares issued at Rs. 12,628.20 per unit were deemed appropriately valued under prescribed rules. The tribunal specifically noted that different valuation methodologies cannot be arbitrarily applied when an initial valuation has been correctly determined. Consequently, the revenue's appeal was comprehensively dismissed, upholding the original assessment and protecting the assessee from supplementary tax liability on share issuance.
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