2026 (2) TMI 315

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....sh Kumar Dhanesta, Sr. DR ORDER PER ANUBHAV SHARMA, JM: This appeal is preferred by the Revenue against the order dated 28.10.2024 of the Ld. National Faceless Appeal Centre (NFAC), Delhi (hereinafter referred as Ld. First Appellate Authority or in short Ld. 'FAA') in DIN & Order No : ITBA/NFAC/S/250/2024-25/1069998832(1)arising out of the order dated 30.12.2017 u/s 143(3) of the Income T....

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.... of difference in fair market value of shares of companies against purchase cost shown by the assessee. 4. The ld. DR and the department asserts that relief has been granted without verifying fair market value of shares submitted by assessee during appellate proceedings and ld. DR has relied the provisions of Rule 46A of Income Tax Rules 1962 to submit that additional evidences were admitted wi....

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.... the Assessing Officer. 6. As we appreciate the impugned order of Ld. CIT(A) we find that though not specifically mentioned that additional evidences have been admitted the ld. CIT(A) has benefitted the assessee primarily relying a decision in the case of Minda S. M. Technocast (P) Ltd. 92 Taxmann.com 29, for the proposition that while valuing the shares, the book value of the assets and liabil....