Assessee Must Prove Valuation Accuracy for Share Premiums u/s 56(2)(viib) Using DCF Method and Empirical Data.

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....Income from other sources - addition u/s 56(2)(viib) - Method of valuation of shares issued at premium - FMV - The primary onus to prove the correctness of the valuation Report is on the assessee as he has special knowledge and he is privy to the facts of the company and only he has opted for this method. Hence, he has to satisfy about the correctness of the projections, Discounting factor and Terminal value etc. with the help of Empirical data or industry norm if any and/or Scientific Data, Scientific Method, scientific study and applicable Guidelines regarding DCF Method of Valuation. - AT....