Court-Approved Scheme: AO's Valuation Date Error u/s 56(2)(vii)(b) on Share Transfer to Holding Company.

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....Addition u/s. 56(2)(vii)(b) - difference in the value of shares transferred by the assessee company to its holding company, pursuant to a scheme approved by the Hon’ble Jurisdicational High Court - the appointed date is 01/04/2013 and hence, the value considered by the assessee, which is nearer to the date is appropriate. The valuation date taken by the AO is not in accordance with the appointed date approved by Hon’ble High Court and in this view of the matter appointed date taken and the valuation done by the AO is incorrect. - AT....