method not
allowed in rule 11UA but that rule allow two methods discounted
free cash flow method and 'Book value of net asset method ... method not
allowed in rule 11UA but that rule allow two methods discounted
free cash flow method and 'Book value of net asset method
contention of the AO to value the shares based only
on net asset method. Further Ld. CIT(A) rejected the valuation ... method prescribed in rule
11UA i.e. either net asset method or DCM method. As per the
above rule, assessee has appointed a merchant banker
Method'
and then, alternatively, had submitted that even the 'Net Asset
Method' could also be applicable and the valuation of the land ... viib) of the Income Tax Act, 1961 both
by the 'Net Asset Method' and by the 'Discounted Cash Flow
Method
Cash Flow method;..................."
10. Clause (a) and (b) of the Rule 11UA(2) of
the Rule prescribes the method of Net
Asset Value method ... learned Assessing
Officer needs to examine that
method. Naturally, if the
discounted cash flow method and net
asset value method gives the same
result, where
following, whichever is beneficial to the company
valuation based of Net Asset Value Method, with
certain modifications prescribed u/r 11UA ... submits that the Ld AO was not justified in
invoking Net Asset Method in place of Discounted
Cash Flow Method adopted by the appellant
Page
averaging
the valuation as per PECV method as well as net asset
value method. He submitted that when the legislation
has conferred an option ... assessee
either to apply the DCF method or net asset valuation
method, this option is not available to the assessing officer.
Rule 11UA provides
also upholding the merger method for accounting
the amalgamation and net asset value method instead of
discounted cash flow method to compute the goodwill ... net assets vesting in the assessee company
as a result of amalgamation. The net book value of the assets
(assets - liabilities) of the amalgamating company
shares by the
assessee company as per the "Net Asset Value" (NAV) Method, which was strictly
as per the mandate of "Explanation ... preference shares could safely be carried out as per "Net Asset Value" method as
was so done by the present assessee company
short "DCF"]
method and substituted by applying the Net Asset Method [in
short "NAV"].
3. The learned Authorised Representative ... learned Assessing
Officer needs to examine that method. Naturally, if the discounted cash
flow method and net asset value method gives the same result, where
value based on the Net Asset
Method second method mention in Income tax rules. The detail
calculation/working under Net Asset Value method ... corroborated with another method of valuation,
accordingly the fair value arrived under DFCF method is
corroborated with valuation as per Net Asset Value
Method