Assessee company which was said to be incorporated on 7-11-2012 issued shares at a premium on 16-11-2012 and charged premium of Rs. 25 per share on preference shares of face value of Rs. 100 each and Rs. 2. 5 per share on equity shares having face value of Rs. 10 each. Assessee obtained a valuation report from registered valuer, prepared as per rule 11UA(2)(b), justifying charging of said share premium. Said report was considered by Commissioner (Appeals) and claim of assessee was accepted by deleting addition made by Assessing Officer. On appeal, revenue submitted that inclusion of subsidiary companies for preparing valuation report was not justified as they had been acquired after valuation date. Since in valuation report prepared by CA, fair market value of equity share and preference share had been arrived at mainly after considering net-worth of two step down subsidiaries, however, fact of acquiring wholly owned subsidiaries/step down subsidiaries after cut-off date of valuation of share was not provided to CA, results arrived at in valuation report could not have been accepted. Share premium of Rs. 2. 50 per share on issue of equity share capital and share premium of Rs. 25 per share received on issue of preference share capital along with face value of each equity share at Rs. 10 and each preference share at Rs. 100 was in excess of fair market value of Rs. 10 per equity share and Rs. 100 per preference share for preference and therefore, provisions of section 56(2)(viib) had rightly been invoked by Assessing Officer for making addition towards share premium in hands of assessee. (AY. 2013-14)