https://www.taxtmi.com/caselaws?id=791867 For section 56(2)(vii)(c), the fair market value of shares had to be determined strictly under Rule 11UA as it stood for the relevant assessment years, so unquoted shares were valued on the prescribed book value basis. The later amendment allowing a look-through valuation of underlying shares and securities operated only from 01.04.2018 and could not be applied retrospectively to substitute the value of the shares actually acquired. The allegation of a colourable device did not displace the statutory valuation method. The addition was therefore unsustainable, the first appellate deletion was upheld, and the Revenue's appeals failed. en-us Fri, 15 May 2026 00:00:00 +0530 Tue, 19 May 2026 08:18:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791867 For section 56(2)(vii)(c), the fair market value of shares had to be determined strictly under Rule 11UA as it stood for the relevant assessment years, so unquoted shares were valued on the prescribed book value basis. The later amendment allowing a look-through valuation of underlying shares and securities operated only from 01.04.2018 and could not be applied retrospectively to substitute the value of the shares actually acquired. The allegation of a colourable device did not displace the statutory valuation method. The addition was therefore unsustainable, the first appellate deletion was upheld, and the Revenue's appeals failed. Case-Laws Income Tax Fri, 15 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791867