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    <title>2026 (7) TMI 478 - ITAT DELHI</title>
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    <description>Section 56(2)(viib) applied on receipt basis where share consideration was received in the relevant previous year, even though allotment had occurred earlier, so the challenge to its applicability failed. On valuation, Rule 11UA allowed the assessee to use a recognised DCF method, and the Assessing Officer could not reject that valuation merely because later results differed from projections. The valuation report was not shown to be methodologically defective, and tax could be levied only on the excess over fair market value, not on the entire share premium. On the facts, the share premium was not shown to exceed fair market value, so the addition was unsustainable.</description>
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      <link>https://www.taxtmi.com/caselaws?id=794592</link>
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