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TMI Blog2021 (7) TMI 1442X X X X Extracts X X X X X X X X Extracts X X X X ..... ed the addition on the grounds that once Rule 11UA has been notified by the CBDT, the rule would be applicable for the entire assessment year and not for the transactions done after 29.11.2012 - as submitted that the amounts have been received as loans initially which were subsequently converted into share capital HELD THAT:- The amounts have utilized for purchase of land and if the cost of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e in order by the revenue authorities, we hereby decline to interfere with the order of the ld. CIT (A). Decided against revenue. - SH. AMIT SHUKLA, JUDICIAL MEMBER AND DR. B. R. R. KUMAR, ACCOUNTANT MEMBER For the Assessee : Sh. K. Sampath, Adv. Sh. V. Raj Kumar, Adv. For the Revenue : Ms. Alka Gautam, Sr. DR ORDER PER DR. B.R.R. KUMAR, ACCOUNTANT MEMBER: The prese ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (2) r.w.s. 2(14) of the Income Tax Act, 1961. The AO determined the book value as (A-L) PV PE as per the formula under Rule 11UA on NAV basis. The AO further held that the amendment to Rule 11UA is applicable from the date of notification i.e. 29.11.2012, hence the assessee cannot have the benefit of valuation based on Discounted Cash Flow (DCF) method. 5. The ld. CIT (A) deleted the addition ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... submitted to the ld. CIT (A) as additional evidence has been accepted by the revenue and no inconsistencies in the valuation report has been brought out by the revenue. 7. Since, the source of the amounts received has not been the issue before us, since the valuation report as per the DCF method is an acceptable method prescribed under Rule 11UA in relation to Section 56(2)(viib) and since the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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