Assessee company had issued shares of face value of Rs. 10/- each at a premium of Rs. 14.70 per share and, accordingly, received share premium . Shares were issued after duly valuing shares based on Discount Cash Flow (DCF) method and valuation was done by a merchant banker . AO held that valuer had not independently valued prospects of assessee company and merely relied on information supplied by assessee and; accordingly, he proceeded to value fair market value of shares based on Net assets value added method. CIT(A) accepted DCF method adopted by assessee,  however, he proceeded to compare projections adopted by valuer with actual results or actual performance of assessee company in subsequent years and arbitrarily he held that business was growing at 40 per cent and, hence, enterprise value of assessee should also be taken up by merchant banker. CIT(A) determined share value at Rs. 11.17 per share and excess of amount received by assessee was treated as addition under S.  56(2)(viib) of the Act.  On appeal the Tribunal held that  the AO and CIT (A)were trying to evaluate accuracy of valuation at time of assessment, and this was not proper and also factual results of company were based on so many factors subsequent to adoption of projection and valuation and, thus, finding of AO and CIT (A) could  not be upheld .