https://www.taxtmi.com/caselaws?id=786487 Issue concerns chargeability of excess share premium under Section 56(2)(viib) where the assessee used the Discounted Cash Flow (DCF) method under Rule 11UA. The DCF valuation must be judged on reasonableness of projections and contemporaneous supporting materials; authorities may scrutinise inputs but may not substitute a different prescribed method. Substitution to a net asset value approach using book values and ignoring contemporaneous market indicators is impermissible. Applying NAV with prevailing market values can produce FMV above the issue price, removing taxability. On these facts the DCF report was sustained and the addition of Rs.10,21,00,000 under Section 56(2)(viib) was deleted. en-us Tue, 10 Feb 2026 00:00:00 +0530 Fri, 13 Feb 2026 09:18:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786487 Issue concerns chargeability of excess share premium under Section 56(2)(viib) where the assessee used the Discounted Cash Flow (DCF) method under Rule 11UA. The DCF valuation must be judged on reasonableness of projections and contemporaneous supporting materials; authorities may scrutinise inputs but may not substitute a different prescribed method. Substitution to a net asset value approach using book values and ignoring contemporaneous market indicators is impermissible. Applying NAV with prevailing market values can produce FMV above the issue price, removing taxability. On these facts the DCF report was sustained and the addition of Rs.10,21,00,000 under Section 56(2)(viib) was deleted. Case-Laws Income Tax Tue, 10 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786487