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    <title>DCF share valuation cannot be replaced without defect; protective addition fails when taxability uncertainty is absent.</title>
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    <description>DCF share valuation could not be discarded and replaced with another fair market value without first identifying a specific defect or non-compliance in the assessee&#039;s prescribed valuation report, so the addition for excess share premium under section 56(2)(vii)(b) was deleted. Protective assessment was confined to cases of doubt about the correct person chargeable to tax; where both additions were made in the same assessee&#039;s hands in the same year under different heads, that basis did not apply, so the section 68 protective addition was also deleted. The appeal was allowed.</description>
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    <pubDate>Tue, 28 Apr 2026 07:29:33 +0530</pubDate>
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      <title>DCF share valuation cannot be replaced without defect; protective addition fails when taxability uncertainty is absent.</title>
      <link>https://www.taxtmi.com/highlights?id=99247</link>
      <description>DCF share valuation could not be discarded and replaced with another fair market value without first identifying a specific defect or non-compliance in the assessee&#039;s prescribed valuation report, so the addition for excess share premium under section 56(2)(vii)(b) was deleted. Protective assessment was confined to cases of doubt about the correct person chargeable to tax; where both additions were made in the same assessee&#039;s hands in the same year under different heads, that basis did not apply, so the section 68 protective addition was also deleted. The appeal was allowed.</description>
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      <pubDate>Tue, 28 Apr 2026 07:29:33 +0530</pubDate>
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