https://www.taxtmi.com/caselaws?id=435383 ITAT DELHI-AT held that the AO erred in discarding the DCF-based FMV and substituting NAV for valuation of shares issued to the wholly-owned holding company. Applying s.56(2)(viib)'s deeming fiction narrowly and following the HC view in analogous precedent, the Tribunal found no justification to treat the premium as taxable income where an independent valuer used the prescribed DCF method and the issue was to the holding company. The appellate order overturning the addition was upheld and the appeal decided against revenue. en-us Wed, 15 Mar 2023 00:00:00 +0530 Thu, 28 Aug 2025 12:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=435383 ITAT DELHI-AT held that the AO erred in discarding the DCF-based FMV and substituting NAV for valuation of shares issued to the wholly-owned holding company. Applying s.56(2)(viib)'s deeming fiction narrowly and following the HC view in analogous precedent, the Tribunal found no justification to treat the premium as taxable income where an independent valuer used the prescribed DCF method and the issue was to the holding company. The appellate order overturning the addition was upheld and the appeal decided against revenue. Case-Laws Income Tax Wed, 15 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=435383