2021 (7) TMI 1464

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.... : Shri Pradeep Kumar, D.R. ORDER PER B.R. BASKARAN, ACCOUNTANT MEMBER: The appeal filed by the assessee is directed against the order dated 21.03.2019 passed by Ld CIT(A)-3, Bengaluru and it relates to the assessment year 2015-16. All the grounds urged by the assessee relate to the addition of Rs. 16.20 crores made by the AO u/s 56(2)(viib) of the Income-tax Act, 1961 ['the Act'....

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....n received by such issuing Company in excess of the FMV, to the extent it exceeds the face value of such shall be liable to tax. 3. The assessee furnished a valuation report dated 22.01.2015 issued by a Chartered Accountant. The AO noticed that the valuation has been done under "Discounted Cash Flow" method. The AO noticed that the value of per share, as per projections was Rs. 37.49 per sha....

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....ional evidence filed by the assessee. The AO expressed the view that the corrigendum issued by the valuer is an afterthought of the assessee. He also expressed the view that the valuation report cannot be changed as per whims and fancies of the assessee. The Ld CIT (A) confronted the remand report of the AO with the assessee. After considering the reply filed by the assessee, the Ld CIT (A) first ....