Dismissing the appeal of the revenue the Court held that, the amount was never received by the assessee but rather remained with the company of which the most significant control went to the purchaser. In these circumstances, the rejection of the valuation and the amount brought to tax by the AO was correctly held by the lower appellate authorities to be unjustified. In view of this concurrent findings of fact, no substantial question of law arise on this aspect.
PCIT v. Gyan Enterprises (P.) Ltd (2020) 117 taxmann.com 113 (Delhi)(HC) Editorial : SLP of revenue is dismissed, PCIT v. Gyan Enterprises (P) Ltd (2020) 274 Taxman 107 (SC)
S. 143(3) : Assessment-In adequate sale consideration based on valuation report-Deletion of addition is held to be justified.