Section 50CA share valuation must follow Rule 11UAA and Rule 11UA(1); CA valuation sustained, addition deleted.

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....For section 50CA, valuation of unquoted equity shares must follow Rule 11UAA read with Rule 11UA(1), and the Assessing Officer could not insist on a merchant banker report by importing the regime meant for section 56(2)(viib). The assessee's Chartered Accountant valuation under the Net Asset Value method showed a fair market value below the actual sale price, so the declared consideration could not be substituted merely because fresh shares had earlier been issued to the same buyer at a higher price. The ITAT upheld deletion of the addition, finding no basis for an adjustment under section 50CA.....