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INCOME TAX APPELLATE TRIBUNAL (CHENNAI BENCH)
Shri Manu Kumar Giri, J, Shri S.R. Raghunatha, AM
M/s. Ambattur Developers Private Limited – Appellant
Versus
Income Tax Officer, Corporate Ward- 1(1) – Respondent
| Table of Content |
|---|
| 1. introduction of appeal and facts regarding tax assessment. (Para 1 , 3) |
| 2. arguments presented by the assessee. (Para 2 , 6) |
| 3. court's observations on share valuation and intent behind section 56(2)(viib). (Para 5 , 8 , 12) |
| 4. key findings on the brand's value and factors enhancing asset valuation. (Para 9 , 10 , 17) |
| 5. conclusion to allow the assessee's appeal. (Para 18 , 19) |
आदेश/ORDER
PER S.R.RAGHUNATHA, AM :
This appeal by the assessee is filed against the order of the learned Commissioner of Income Tax (Appeal), NFAC, Delhi, (in short Ld.CIT(A)) for the assessment year 2015-16, vide order dated 12.08.2024.
2. The grounds raised by the assessee are as follows:
1) The Order of the Commissioner of Income tax, National Faceless Appeal Centre (NFAC), Delhi is contrary to law, facts and in the circumstances of the case.
2) The CIT(A) NFAC erred in confirming the addition made under section 56(2)(vii)(b) to the extent of Rs. 72,69,89,420/- in respect of shares allotted at a premium of 1,767/- per share.
3) The CIT(A) / NFAC erred in estimating the Fair market value of shares at 837.24 per shares instead of Rs.1,777/- as submitted by the Appellant.
4) The CIT(A) /NFAC should h
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