Caddie Hotels (P.) Ltd. v. PCIT (2023) 202 ITD 351 (Delhi) (Trib.)

S. 56 : Income from other sources-Valuation of shares-Two methods-NAV or DCF-Choice with the assessee-The Assessing Officer cannot question valuation per se. [R.11UA]

Tribunal held that valuation of unquoted equity shares in terms of rule 11UA can be determined by assessee as per either NAV Method or as per Discounted Free Cash Flow Method and, Assessing Officer is bound to follow same unless by bringing cogent material on record, Assessing Officer establishes perversity in method adopted by assessee. Once value of shares had been determined by adopting any of two methods, i.e. NAV or DCF, then such value shall be deemed to be FMV of assessee company and Assessing Officer could not have questioned valuation per se.  (AY. 2014-15 to 2017-18)