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The AO can scrutinize the valuation report and the if the AO is not satisfied with the explanation of the assessee, he has to record the reasons and basis for not accepting the valuation report submitted by the assessee and only thereafter, he can go for own valuation or to obtain the fresh valuation report from an independent valuer and confront the same to 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.

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Sec. 56(2)(viib) of Income Tax Act, 1961—Income from other sources— For correct valuation of shares, assessee has to satisfy about the correctness of the projections, Discounting factor and Terminal value etc. with the help of Empirical data or industry norm if any and/or Scientific Data, Scientific Method, Scientific study and applicable Guidelines regarding DCF Method of Valuation. - FLUTURA BUSINESS SOLUTIONS PVT. LTD. V/s ITO - [2020] 183 ITD 446 (ITAT-BANGALORE)

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