Held that even if the assessee has obtained the valuation report at a later date, as long as it is able to demonstrate that the FMV has been ascertained in accordance with r. 11UA(1)(c), based on the audited balance sheet drawn up on the valuation date, said report cannot be rejected for being obtained post the date of transaction; Revenue was empowered to ascertain the FMV of shares only in accordance with the specific and sole method as prescribed in r. 11UA(1)(c) and could not apply any alternate methodology, viz., external comparable method; while arriving at the FMV of unquoted shares held by the company IG3, the resultant negative figure arising on account of excess of liabilities over the value of assets cannot be ignored; loan granted to other companies cannot be considered as amount set apart as dividend, having regard to the language used in r. 11UA(1)(c); FMV of shares of IG3 of Rs. 11.989 per share computed by the assessee was justified; further, ETL held shares of IG3 which have been valued by the assessee at Rs. 11.989 per share, and consequently, the FMV of ETL shares computed by the assessee at Rs. 13.41 per share is justified. Addition was deleted. (AY.2021-22)