Assessee purchased shares of a company for a total consideration of Rs. 1. Assessing Officer held that shares were traded on the stock exchange and lowest price traded was Rs. 22.88 per share; thus, FMV on the date of transfer was Rs. 22.88 per share. Accordingly, he made an addition.  On appeal, the assessee explained that shares purchased by it were under lock-in as per requirements of SEBI Regulations 2009; hence, such shares did not qualify as quoted shares as defined under rule 11U and, therefore, shares were required to be valued as per rule 11UA(1)(c)(b). As per the Valuation Report, the FMV of shares purchased by the assessee was negative. CIT(A) deleted the additions. On appeal, the Tribunal held that nowhere was it emanating from the assessment order or the order of the Commissioner (Appeals) that the period of lock-in of shares purchased by the assessee was discussed. Further, the class of shares purchased by the assessee i.e. shares purchased by assessee were also listed on the stock exchange was also not emanate from the  order. The mere fact that shares were in lock-in was not sufficient to come to the conclusion that market value shall be determined in a manner similar to that of unquoted shares i.e. in accordance with rule 11UA.  Assessing Officer should examine the relevance and impact of the issuance of convertible warrants to the outgoing promoter on the FMV of shares. Accordingly, the issue was restored to the Assessing Officer for de novo assessment. (AY. 2015-16)