2018 (8) TMI 1198

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....(DR)(ITAT), Bengaluru ORDER This is an appeal by the assessee against the order dated 09.03.2018 of the CIT(Appeals). Bengaluru-6, Bengaluru relating to assessment year 2014-15. 2. The assessee is a private limited company. The assessee was incorporated on 4th December, 2012. The assessee is a Software Company engaged in the business of technology service and platform organization. The as....

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....one on par basis. 5. During the year, the company also allotted 35,64,516 Shares of Rs. 1/- each to one M/s. Nature Eco Ventures at Rs. 2.81 per share including premium of Rs. 1.81/- per share. From this allotment, the assessee received premium of Rs. 64,35,484/-. The allottee is a totally independent entity. This allotment was based on a valuation report given by an independent valuer. As per ....

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.... report do not tally with actuals; (c) no basis is given for the projected figures; (d) growth rate is taken as 5.17% have no factual basis: (e) the report is justified based on the details given by the management. 7. Aggrieved by the above, the assessee filed appeal before the CIT(Appeals). 8. Before the CIT(Appeals), the assessee filed written submissions on 06.0....

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...., the valuation is based on self serving data provided by the management to ensure a higher market value and not a fair market value. The subsequent financial results of the appellant only confirm the observations of the AO. Therefore addition made is sustained." 9. The ld. counsel for the assessee submitted that the assessee has filed another submission substantiating as to how the DCF method ....