https://www.taxtmi.com/caselaws?id=450078 The ITAT Delhi quashed the PCIT's revision order under Section 263 regarding valuation of shares under Section 56(2)(x)(c)(B). The assessee had adopted the DCF method for share valuation, which was accepted by the AO after elaborate enquiry. The PCIT contended this was erroneous as fair market value exceeded purchase consideration. The ITAT held that since the statute provides option to adopt either NAV or DCF method, and the AO had taken a plausible view after proper enquiry, the revision was unjustified. Following SC precedent in Canara Bank Securities Ltd and Malabar Industrial Co. Ltd, the ITAT ruled that where two views are possible and AO adopts one after due enquiry, Section 263 powers cannot be invoked. The assessee's appeal was allowed. en-us Fri, 23 Feb 2024 00:00:00 +0530 Tue, 27 Feb 2024 13:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450078 The ITAT Delhi quashed the PCIT's revision order under Section 263 regarding valuation of shares under Section 56(2)(x)(c)(B). The assessee had adopted the DCF method for share valuation, which was accepted by the AO after elaborate enquiry. The PCIT contended this was erroneous as fair market value exceeded purchase consideration. The ITAT held that since the statute provides option to adopt either NAV or DCF method, and the AO had taken a plausible view after proper enquiry, the revision was unjustified. Following SC precedent in Canara Bank Securities Ltd and Malabar Industrial Co. Ltd, the ITAT ruled that where two views are possible and AO adopts one after due enquiry, Section 263 powers cannot be invoked. The assessee's appeal was allowed. Case-Laws Income Tax Fri, 23 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450078