https://www.taxtmi.com/caselaws?id=769750 ITAT Jaipur allowed the appeal regarding unexplained credit under Section 56(2)(viib). The AO rejected the company's DCF valuation method for preference shares and applied NAV method instead, adding excess premium as income. ITAT held that under Rule 11UA(1)(c), the assessee could choose between NAV or DCF methods for preference share valuation. Once chosen, tax authorities cannot disregard the method without basis. The differential treatment between resident and NRI investors was contradictory. Section 115BBE amendment was not given retroactive effect as it wasn't applicable when share capital was received. Additions were deleted. en-us Mon, 28 Apr 2025 00:00:00 +0530 Thu, 01 May 2025 08:46:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769750 ITAT Jaipur allowed the appeal regarding unexplained credit under Section 56(2)(viib). The AO rejected the company's DCF valuation method for preference shares and applied NAV method instead, adding excess premium as income. ITAT held that under Rule 11UA(1)(c), the assessee could choose between NAV or DCF methods for preference share valuation. Once chosen, tax authorities cannot disregard the method without basis. The differential treatment between resident and NRI investors was contradictory. Section 115BBE amendment was not given retroactive effect as it wasn't applicable when share capital was received. Additions were deleted. Case-Laws Income Tax Mon, 28 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769750