Held that the assessee’s valuation report obtained from a chartered accountant in compliance with the requirement of rule 11UA(1)(c)(c) for the purpose of valuation of equity and preference shares, considered the guideline value of the land and building, which was correct. The guideline value of land and building was applied to arrive at the fair value of the preference shares based on what the former would fetch in the open market on the date of valuation and thereby reckon the premium value for the redemption of the preference shares. Therefore, the addition made by the Transfer Pricing Officer to compute the differential premium based on the book value of assets was not sustainable. As no addition could be made towards the premium on redemption of the preference shares, the addition made by the Commissioner (Appeals) treating it as deemed dividend under section 2(22)(e) would not survive. That the premium paid by the assessee for the redemption of preference shares was neither towards reduction of share capital nor towards an advance or loan. Such excess premium paid to AP could not be taxed under section 2(22)(d) or 2(22)(e). The addition made by the Commissioner (Appeals) was deleted. (AY. 2009-10, 2010-11)