Section 56(2)(viib) and Fair Market Value: Share Premium Valuation via DCF Requires Certification by Experts, Not Adjusted by Assessing Officer.

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....Addition u/s 56(2)(viib) - issue of shares at premium - Determination of fair market value - The very purpose of certification of DCF valuation by a merchant banker or chartered accountant is to ensure that the valuation is fair and reasonable. Such valuation is to be done by an expert of the subject only, which an assessing officer is not expected to be. The said rule provides that such valuation shall be the fair market value for the purpose of this section based on DCF Method. The Rule nowhere permits the AO to make any adjustment therein. - AT....