case, the CIT(A) was
justified in holding that the Discounted Cash Flow (DCF) valuer, M/s Machiraju
and Associates has not included a disclaimer ... under implementation and yet to commence
commercial operations, we have adopted discounted cash flow
method for the valuations of shares of M.L.R. Auto
projected financial values in original valuation,
completely disregarding the fact that Discounted Cash Flow
('DCF") method of valuation takes into account future
projections ... shares of
SIPL was determined by an independent valuer by following
Discounted Cash Flow Method at INR 8,042.98/- which was same as
the actual
have erred in applying Discounted Cash Flow ('DCF') to
determine the value of shares of USL at INR 2,039.25.
12. The learned ... conduct an
independent valuation of shares of USL by applying Discounted Cash Flow
(DCF) method based on the data available in Bloomberg database. Based
further verified the
valuation report and found that assessee has used
Discounted Cash Flow (DCF) and Net Asset Value
(NAV) method for valuation of shares ... sheet of the assessee is used. For the valuation,
according to Discounted Cash Flow method, she
stated that valuation is ₹16.38 per share. She
referred
flow for 12.31
Equity
Discounting 0.99 0.87 0.77 0.68 0.60 0.53
Factor
Discounting - 78.83 88.24 59.15 64.76
Cash Flow 10.75
Terminal 1461
Value
Discounted ... cash
flow method is discussed from Page no. 5 to Page no. 11 wherein
the three key pre-requisites (viz cash flow projections, discount
rate
Assessing Officer had rejected the valuation of
shares as per discounted cash flow method applied by
the assessee on the grounds of being unfounded ... recommended the FMV of Rs. 500.06 per share based
on discounted cash flow statement but the shares were
allotted at much higher price than fair
most critical input of the Discounted Cash Flow model is
the cash flow projections. As stated earlier, the Discounted Cash Flow
value is as good ... considered separately. The past unabsorbed tax shelter is valued by using
discounted cash flow method, for the actual years in which the tax shelter
would
whereas the valuer of the Assessee had followed the
'Discounted Free Cash Flow' or 'DCF' method for valuation of
the shares ... fair market value of the shares
onl y on the Discounted Cash Flow Method (the DCF Method),
which was appropriately followed by the Respondent-Assessee
Rule 11UA(2)(b) of Income Tax
Rules, 1962 i.e., Discounted Cash Flow Method.
3. That the Ld. CIT(A) has erred ... Rule 11UA (2) (b) of the Income Tax Rules i.e. Discounted
Cash Flow Method (DCF Method). The Ld. Counsel for the assessee submitted
that
Rule 11UA(2)(b) of
Income Tax Rules, 1962 i.e., Discounted Cash Flow Method.
3. That the Ld. CIT(A) has erred ... Rule 11UA (2) (b) of the Income Tax Rules i.e. Discounted
Cash Flow Method (DCF Method). The Ld. Counsel for the assessee submitted
that
