Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Section 56(2)(viib) read with Rule 11UA allows an assessee to choose a prescribed valuation method for unquoted shares, including a DCF valuation supported by a merchant banker or valuer. The AO cannot independently replace that chosen method with NAV merely because later financial results differ from projections, since valuation is a matter of estimation and not exact science. Applying that principle, the ITAT held the AO's rejection of the DCF report and substitution of NAV to determine fair market value was not permissible and set aside the addition.
Section 56(2)(viib) read with Rule 11UA allows an assessee to choose a prescribed valuation method for unquoted shares, including a DCF valuation supported by a merchant banker or valuer. The AO cannot independently replace that chosen method with NAV merely because later financial results differ from projections, since valuation is a matter of estimation and not exact science. Applying that principle, the ITAT held the AO's rejection of the DCF report and substitution of NAV to determine fair market value was not permissible and set aside the addition.
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