The Transfer Pricing Officer rejected the valuation of shares based on the Discounted Cash Flow (DCF) method by replacing projected financial figures with actual financial results of subsequent years and made a transfer pricing adjustment. The Tribunal held that valuation under the DCF method has to be based on information available on the valuation date and not on hindsight. Rule 10B permits only contemporaneous data and does not authorise reliance on subsequent years’ financial results. Accordingly, substitution of projected figures with actual results was held to be impermissible, and the transfer pricing adjustment was deleted. (AY. 2017-18).