ITAT Upholds DCF Valuation Under Section 56(2)(viib) and Allows Depreciation on Intangible Rights

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....The ITAT upheld the deletion of addition under Section 56(2)(viib) relating to security premium, affirming that the assessee's reliance on the Discounted Cash Flow (DCF) valuation report by a Chartered Accountant is valid. The AO cannot substitute or question the fair market value determined using prescribed methods under the Act and Rules. Additionally, the ITAT confirmed the allowability of depreciation on a non-refundable deposit paid for acquiring intangible rights to operate and manage a hospital, recognizing it as a depreciable intangible asset. This aligns with precedent affirming that transferable intangible rights qualify for depreciation. The Revenue's appeal was dismissed in its entirety.....