https://www.taxtmi.com/highlights?id=102630 Discounted Cash Flow valuation of shares issued by a newly incorporated company was recognised as a valid method for section 56(2)(viib) purposes, even before its later notification under Rule 11UA. Recognition by valuation professionals was distinguished from legislative notification, and the Net Asset Value method was considered unsuitable for a newly incorporated company. Although the valuation rule used mandatory language, the Assessing Officer was required to identify defects in the valuation report or methodology and could not replace projected returns with an independent estimate. Procedural valuation rules could not defeat substantive rights without a substantial legal breach. The share-premium addition was deleted and that deletion was affirmed. en-us Wed, 12 Aug 2026 09:30:57 +0530 Wed, 12 Aug 2026 09:30:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=102630 Discounted Cash Flow valuation of shares issued by a newly incorporated company was recognised as a valid method for section 56(2)(viib) purposes, even before its later notification under Rule 11UA. Recognition by valuation professionals was distinguished from legislative notification, and the Net Asset Value method was considered unsuitable for a newly incorporated company. Although the valuation rule used mandatory language, the Assessing Officer was required to identify defects in the valuation report or methodology and could not replace projected returns with an independent estimate. Procedural valuation rules could not defeat substantive rights without a substantial legal breach. The share-premium addition was deleted and that deletion was affirmed. Highlights Income Tax Wed, 12 Aug 2026 09:30:57 +0530 https://www.taxtmi.com/highlights?id=102630