AO Cannot Replace DCF with NAV Simply Due to Projection Variances

JCIT Vs GTR Aluminium Pvt. Ltd. (ITAT Bangalore) DCF Method Chosen by Assessee Is Binding—AO Cannot Switch to NAV Merely Because Projections Differ; Karnataka HC Ruling in Waterline Hotels Applied The Revenue appealed against the order of CIT(A)/NFAC dated 12-10-2023 deleting the addition of ₹5,22,24,080 made u/s 56(2)(viib) on the ground that the Assessee’s share valuation under the DCF method was correct and the AO could not substitute it with the NAV method. The Tribunal first condoned a 50-day delay in Revenue’s filing, noting sufficient cause. GTR Aluminium Pvt Ltd had issued 1,09...