During the course of assessment proceedings, Ld. AO noted that assessee company collected Rs.2,45,02,463/- as  securities premium on issue of shares. Ld. AO asked assessee to substantiate the share premium so collected. In response, assessee submitted certificate obtained by Chartered Accountant. The valuation adopted by the assessee found to be as per DCF. However, Ld. AO held that the valuation of the assessee cannot be accepted without verifying the credibility of the data provided by the assessee. Accordingly, Ld. AO rejected the valuation of the assessee and adopted NAV method and thus made an addition of Rs.1,12,21,109/-. On appeal, CIT(A) upheld the order of Ld. AO. Aggrieved by the same, assessee appealed before the ITAT. The Tribunal held that AO can scrutinize the valuation report and if he is not satisfied with the explanation of the assessee, he has to record the reasons and basis for not accepting the valuation report submitted by the assessee. Only thereafter, he can go for own valuation or to obtain the fresh valuation report from an independent valuer and confront the same to the assessee. But the basis has to be DCF method and he cannot change the method of valuation which has been opted by the assessee. Further for scrutinizing the valuation report, the facts and data available on the date of valuation only has to be considered and actual result of future cannot be a basis to decide about reliability of the projections. The Tribunal further held that primary onus to prove the correctness of the valuation report is on the assessee as he has special knowledge and he is privy to the facts of the company and only he has opted for this method. Hence, he has to satisfy about the correctness of the projections, Discounting factor and Terminal value etc. with the help of Empirical data or industry norm if any and/or Scientific Data, Scientific Method, scientific study and applicable Guidelines regarding DCF Method of Valuation. With this observations the Tribunal restored the matter back to Ld. AO for a fresh decision. (ITA No. 1278/Bang/2018,  dt. 09.01.2019, A.Y. 2014-15)