follows:-
"16. In our considered opinion, the language of rule 11UA(2)
indubitably places a choice upon the assessee to either follow the
route ... conjoint reading of section
56(2) (viib) read along with rule 11UA(2), the option and the
choice stands vested solely in the hands
thereafter noticed the provisions made in Rule 11UA of
the Income Tax Rules, 1962 ["Rules"]. However, and which fact is
ITA 741/2019 ... multiple reasons as discussed (Supra), now sub-clause
(a) of Rule 11UA(2) is to be considered which provides for
computation of the fair market
similar nature.
Whichever is higher.
5.5 According to the provisions of Rule 11UA(2)(b), the assessee
exercised the option of valuation of shares ... entertainment, then such commercial wisdom cannot be
questioned. Even the prescribed Rule 11UA(2) does not give
any power to the Assessing Officer to examine
mischief of
provisions of section 56(2)(viib) read with Rule 11UA(1)cb, the
reasons for which have already been reproduced in the preceding
method which is one of the prescribed method under the rule 11UA.
This is a digitally signed order.
The authenticity of the order
entertainment, then such commercial wisdom cannot be
questioned. Even the prescribed Rule 11UA(2) does not give
any power to the Assessing Officer to examine
purposes of computing consideration. It is in the
aforesaid context that Rule 11UA of the Income Tax Rules, 1962 6
and other cognate provisions would
purposes of computing consideration. It is in the
aforesaid context that Rule 11UA of the Income Tax Rules, 1962 6
and other cognate provisions would
purposes of computing consideration. It is in the
aforesaid context that Rule 11UA of the Income Tax Rules, 1962 6
and other cognate provisions would
purposes of computing consideration. It is in the
aforesaid context that Rule 11UA of the Income Tax Rules, 1962 6
and other cognate provisions would
