ITAT Rajkot Upholds ₹3.99 Crore Addition u/s 56(2)(viib) – Rejects DCF Valuation as Defective & Unsubstantiated

Kataria Snack Pellets Pvt. Ltd. Vs ACIT (ITAT Rajkot)

Assessee, a newly incorporated private limited company engaged in manufacturing snack pellets, filed its return declaring a loss of ₹2.26 crore. The original scrutiny assessment under section 143(3) (dated 27-12-2017) accepted the return. Subsequently, based on INSIGHT portal inputs categorised as high-risk transaction, the AO reopened the case u/s 147 on the ground that the assessee had received share premium of ₹3.99 crore. The company had issued 8,000 shares of ₹10 each at a premium of ₹4,990 per share, valuing them t

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