Valuation under tax law: Estimation vs Actual - High Court upholds ITAT's view, remits case for fresh valuation.

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....Validity of valuation u/s 56(2)(viib) was questioned. The Assessing Officer rejected the assessee's valuation report and framed the order based on actual figures, which was criticized by the CIT(A) and ITAT. The High Court observed that an estimation would be based on approximate evaluation and should not be questioned based on actual facts or figures. The correctness of an estimation should be tested on legitimate and valid assessment. While upholding the ITAT's view, the High Court remitted the matter to the Assessing Officer to undertake valuation afresh considering Section 56(2)(viib), adhering to the DCF Method. If the assessee's data warrants examination, the Assessing Officer can enlist an appropriate valuer's services.....