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        Case ID :
        Income Tax

        ITAT upheld the appellate authority's decision and dismissed the...

        Assessee's elected Rule 11UA/Section 56(2)(viib) DCF valuation upheld; AO cannot substitute NAV or re-determine FMV

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                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.
                                ITAT upheld the appellate authority's decision and dismissed the Revenue's appeal, holding that once the assessee validly elected an approved valuation methodology under Rule 11UA/section 56(2)(viib) (here, the DCF/DFC F method), the Assessing Officer lacked jurisdiction to substitute an alternative approved method (NAV) or re-determine fair market value. The Tribunal found the AO's rejection of the registered valuer's DCF-based valuation and his comparison of projected figures with subsequent actuals impermissible, recognising valuation as a technical exercise for experts and noting investor acceptance of the valuation supported its reasonableness. Consequently the CIT(A)'s findings were affirmed and the addition was deleted.
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