Discrepancies in Share Valuation Projections: Section 56(2)(viib) Only Taxes Excess Premium Over Face Value.

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....Addition u/s. 56(2)(viib) - valuation of shares - the valuer has merely adopted the projections made by the management and there was substantial difference in cash flow projections in both the valuation reports itself. The valuation could not be substantiated by the assessee. We also concur that only excess premium exceeding face value of shares could be brought to tax u/s 56(2)(viib). Therefore, the adjudication as done by Ld. CIT(A) in the impugned order could not be faulted with. - AT....