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M/S. Innaccel Technologies Private ... vs Assistant Commissioner Of Income Tax, ... on 16 December, 2020 cites

Vodafone M-Pesa Limited, Mumbai vs Deputy Commissioner Of Income Circle ... on 13 December, 2019

19. The provisions of Rule 11UA(2)(b) of the Rules provides that, the Assessee can adopt the fair market value as per the above two methods and the choice of method is that of the Assessee. The ITA No.146/Bang/2020 M/s. Innaccel Technologies Pvt. Ltd., Bengaluru Page 10 of 13 Tribunal has followed the judgment of Hon'ble Bombay High Court rendered in the case of Vodafone M-Pesa Ltd., Vs. Pr. CIT (supra) and has taken the view that the AO can scrutinize the valuation report and he can determine a fresh valuation either by himself or by calling a determination from an independent valuer to confront the Assessee but the basis has to be DCF method and he cannot change the method of valuation which has been opted by the Assessee. The decision of ITAT, Delhi in the case of Agro Portfolio Ltd. 171 ITD 74 has also been considered by the ITAT, Bangalore in the case of VBHC Value Homes Pvt.Ltd.(supra).
Income Tax Appellate Tribunal - Mumbai Cites 14 - Cited by 24 - Full Document

M/S Innoviti Payment Solutions Pvt Ltd , ... vs The Income Tax Officer Circle-3(1)(1), ... on 9 January, 2019

6. In the instant case also, the facts are identical, i.e., the AO has proceeded to determine the value of shares by adopting different method without scrutinizing the valuation report furnished by the assessee under DCF method. Accordingly, following the decisions rendered by the co-ordinate benches, we set aside the orders passed by Ld CIT(A) and restore the impugned issue to the file of the AO with the direction to examine this afresh as per the directions given by the co-ordinate bench in the case of Innoviti Payment Solutions P Ltd (supra).
Income Tax Appellate Tribunal - Bangalore Cites 12 - Cited by 21 - Full Document

Gvk Inds. Ltd & Anr vs The Income Tax Officer & Anr on 1 March, 2011

Ltd. Vs. ITO (supra) because this is settled position of law by now that if two views are possible then the view favourable to the assessee should be adopted and with regard to various Tribunal orders cited by learned DR of the Revenue which are against the assessee we hold that because we are following a judgment of Hon'ble Bombay High Court rendered in the case of Vodafone M-Pesa Ltd., Vs. Pr. CIT (supra), these tribunal orders are not relevant.
Supreme Court of India Cites 25 - Cited by 855 - Full Document

Rameshwaram Strong Glass (P.) Ltd., ... vs Ito, Ajmer on 12 July, 2018

In the case of M/s. Rameshwaram Strong Glass (P) Ltd. vs. The ITO (Supra), the tribunal has reproduced relevant portion of another tribunal order rendered in the case of ITO vs. M/s Universal Polypack (India) Pvt. Ltd. in ITA No. 609/JP/2017 dated 31.01.2018. In this case, the tribunal held that if the assessee has opted for DCF method, the AO cannot challenge the same but the AO is well within his rights to examine the methodology adopted by the assessee and/or underlying ITA No.146/Bang/2020 M/s. Innaccel Technologies Pvt. Ltd., Bengaluru Page 5 of 13 assumptions and if he is not satisfied, he can challenge the same and suggest necessary modifications/alterations provided the same are based on sound reasoning and rationale basis.
Income Tax Appellate Tribunal - Jaipur Cites 16 - Cited by 36 - Full Document
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