https://www.taxtmi.com/caselaws?id=763479 ITAT Ahmedabad dismissed Revenue's appeal regarding addition under Section 56(2)(viib) for share valuation. Assessee used DCF method with CA report for equity share FMV determination. AO rejected this valuation and adopted NAV method instead. CIT(A) deleted the addition. ITAT held AO cannot reject assessee's valuation method without referring to independent Registered Valuer/Merchant Banker. AO must use same DCF method chosen by assessee and cannot substitute own valuation without enabling provision. Court relied on Delhi HC precedent establishing AO lacks expertise to reject prescribed expert valuations. Additionally, Section 56(2)(viib) held inapplicable for holding-subsidiary transactions where no income accrues to ultimate beneficiary. en-us Wed, 18 Dec 2024 00:00:00 +0530 Thu, 19 Dec 2024 17:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763479 ITAT Ahmedabad dismissed Revenue's appeal regarding addition under Section 56(2)(viib) for share valuation. Assessee used DCF method with CA report for equity share FMV determination. AO rejected this valuation and adopted NAV method instead. CIT(A) deleted the addition. ITAT held AO cannot reject assessee's valuation method without referring to independent Registered Valuer/Merchant Banker. AO must use same DCF method chosen by assessee and cannot substitute own valuation without enabling provision. Court relied on Delhi HC precedent establishing AO lacks expertise to reject prescribed expert valuations. Additionally, Section 56(2)(viib) held inapplicable for holding-subsidiary transactions where no income accrues to ultimate beneficiary. Case-Laws Income Tax Wed, 18 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763479