Royalty Valuation Must Rely on Expert Report; Independent AO Valuation Deemed Erroneous Under Legal Standards.

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....Determination of value of royalty through a Valuation Report of an expert - In case, AO was not satisfied or convinced with the Valuation Report of the expert valuer, proper course for him would have been to seek opinion of a second valuer on the Valuation Report furnished by the assessee. Instead of doing that, the AO has taken it upon himself to undertake the exercise on valuation of the royalty. This, in our view, is totally erroneous and against settled legal principles. - AT....