ITAT affirmed CIT(A) and dismissed the revenue's appeal, holding...

ITAT affirmed CIT(A) and dismissed the revenue's appeal, holding that under Rule 11UA(2) the assessee had statutory option to adopt either NAV or DCF for valuation of unquoted equity shares for s.56(2)(viib); once the assessee validly exercised the option and furnished a merchant banker's DCF valuation, the AO lacked jurisdiction to unilaterally alter the valuation method. The AO's rejection of the valuation without obtaining an alternative valuation from an authorized valuer under Rule 11UA(2) was impermissible. Absent any admissible contrary valuation, the addition was correctly deleted and the assessment adjustment was reversed in favour of the assessee; appeal by the revenue dismissed.