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ITAT allowed revenue's appeal and remanded the case for de novo assessment. The tribunal found significant procedural gaps in the lower authorities' orders, specifically noting the lack of discussion regarding the share purchase agreement's lock-in period and the precise nature of shares traded. The AO is directed to re-examine the share valuation, particularly considering the convertible warrants issued to the outgoing promoter. The tribunal highlighted insufficient analysis of market value determination under section 56(2)(vii)(c), requiring a comprehensive reassessment of the original valuation approach. The case was restored to the AO for a fresh evaluation of the tax implications.
ITAT allowed revenue's appeal and remanded the case for de novo assessment. The tribunal found significant procedural gaps in the lower authorities' orders, specifically noting the lack of discussion regarding the share purchase agreement's lock-in period and the precise nature of shares traded. The AO is directed to re-examine the share valuation, particularly considering the convertible warrants issued to the outgoing promoter. The tribunal highlighted insufficient analysis of market value determination under section 56(2)(vii)(c), requiring a comprehensive reassessment of the original valuation approach. The case was restored to the AO for a fresh evaluation of the tax implications.
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