https://www.taxtmi.com/caselaws?id=775516 The ITAT Delhi held that the AO erred in substituting the DCF valuation of shares with the NAV method under Rule 11UA, as the shares were allotted only to promoters and no unaccounted money was involved. The AO's reliance on projections rather than actuals was improper, and no evidence questioned the genuineness of the transaction. The subsequent sale of shares to a third party at a higher price supported the valuer's DCF-based valuation. The tribunal affirmed that AO cannot replace DCF with NAV and projections cannot override actual performance. Accordingly, the additions under section 56(2)(viib) were disallowed, and the assessee's valuation method was upheld. en-us Wed, 23 Jul 2025 00:00:00 +0530 Fri, 27 Mar 2026 11:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775516 The ITAT Delhi held that the AO erred in substituting the DCF valuation of shares with the NAV method under Rule 11UA, as the shares were allotted only to promoters and no unaccounted money was involved. The AO's reliance on projections rather than actuals was improper, and no evidence questioned the genuineness of the transaction. The subsequent sale of shares to a third party at a higher price supported the valuer's DCF-based valuation. The tribunal affirmed that AO cannot replace DCF with NAV and projections cannot override actual performance. Accordingly, the additions under section 56(2)(viib) were disallowed, and the assessee's valuation method was upheld. Case-Laws Income Tax Wed, 23 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775516