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ITAT affirmed the CIT(A)'s deletion of an addition under section 56(2)(viib) relating to share premium by upholding the taxpayer's valuation under Rule 11UA. The Tribunal found the AO's contrary view rested on a misconstruction of the valuation methodology and that the valuation report had been correctly prepared; where shareholder net worth is the basis, liabilities need not be separately deducted, whereas if total assets are used liabilities must be excluded, yielding an equivalent net result. CIT(A) had properly appreciated facts and denied the Revenue an opportunity under Rule 46A was not shown to vitiate the adjudication. Accordingly, the ITAT dismissed the Revenue's appeal.
ITAT affirmed the CIT(A)'s deletion of an addition under section 56(2)(viib) relating to share premium by upholding the taxpayer's valuation under Rule 11UA. The Tribunal found the AO's contrary view rested on a misconstruction of the valuation methodology and that the valuation report had been correctly prepared; where shareholder net worth is the basis, liabilities need not be separately deducted, whereas if total assets are used liabilities must be excluded, yielding an equivalent net result. CIT(A) had properly appreciated facts and denied the Revenue an opportunity under Rule 46A was not shown to vitiate the adjudication. Accordingly, the ITAT dismissed the Revenue's appeal.
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