Assessee-company issued shares  at premium  valuing the shares at DCF method. The Assessing Officer accepted the valuation adopted by the Assesee. Commissioner set aside the order and directed the Assessing Officer to adopt NAV method to determine FMV. On appeal the Tribunal held that valuation method opted by assessee could not be changed in view of statutory mandate of rule 11UA(2) and, thus, action of Principal Commissioner is  in direct contravention to provisions of Explanation (a)(i) to section 56(2)(viib) read with rule 11UA. Principal Commissioner also  invoked revisionary proceedings on ground that assessee claimed TDS on interest income, however no such income was offered for tax. On appeal the Tribunal held that  since interest was earned on fixed deposits made for obtaining bank guarantee against EPCG licenses which were availed to import machinery required for construction of assessee’s hotel, said interest was directly linked with activity of setting up hotel and was to be viewed as a capital receipt going to reduce cost of construction.  Revision order is quashed.  (AY. 2016-17)