DCF share valuation cannot be replaced without defect; protective addition fails when taxability uncertainty is absent.

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....DCF share valuation could not be discarded and replaced with another fair market value without first identifying a specific defect or non-compliance in the assessee's prescribed valuation report, so the addition for excess share premium under section 56(2)(vii)(b) was deleted. Protective assessment was confined to cases of doubt about the correct person chargeable to tax; where both additions were made in the same assessee's hands in the same year under different heads, that basis did not apply, so the section 68 protective addition was also deleted. The appeal was allowed.....