Assessee received share premium. AO made addition by stating that assessee valued own shares on NAV method whereas adopted Discounted cash flow method for valuing shares of its wholly owned subsidiary. Thus, AO held excessive premium to be chargeable to tax u/s. 56(2)(viib). ITAT held that to value the business of the holding company, the valuation of subsidiary company is relevant and important for determination of the valuation of the holding company. The whole basis of existence of the holding company depends upon the performance of the subsidiary company. Holding company does not have any activities of its own and all the education and training activities are carried in the subsidiary company. The Tax Authorities has to appreciate the purpose for which the valuation of shares was carried and it should also appreciate the evolution of various valuation methods to suit the purpose. The assessee has brought in new investors and when the new investors are introduced the existing shareholders cannot be at par with the new shareholders by issuing shares at existing Net Asset Value valuation. The new shareholders have to bring in premium to match the goodwill carried on by the existing shareholders. Thus, valuation of shares of subsidiary as per DCF while determining valuation of assessee company as per NAV, was to be accepted and there was no reason to interfere with the method adopted by the assessee (AY. 2017-18)