Valuation for Share Premium on Preference share cannot be made on mere suspicion

DCIT Vs Piramal Realty Pvt. Ltd. (ITAT Mumbai)

We have considered the issue and find that this section does not cover section 68 of the Act. Thus, the Legislature does not envisage any sort of valuation for the purpose of section 68 of the Act. Indeed, valuation of preference shares is a completely different exercise as compared to valuation of equity shares. The AO makes the mention of the reserves and loss while challenging the charge of share premium on preference shares. “Reserves” could be relevant for valui

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