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Corporate TaxArticle·21 August 2026

Madras HC affirms ITAT that Valuation cannot be arbitrary

By J the App

Executive Summary

Can the Revenue reject an accountant’s valuation of unquoted preference shares and substitute a higher value based on one earlier transaction? Madras High Court says no. 

The Court held that Rule 11UA expressly permits an accountant’s report and that the Revenue could not assume that the shares sold were the same block earlier acquired at ₹240. The Tribunal’s acceptance of the ₹101.93 valuation was therefore upheld.

Domain | Corporate tax | Income Tax | Section 56(2)(viia) | Share Valuation

The Position

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