During the year under consideration, the assessee Geon Studio Pvt. Ltd. has issued 610825 Non-cumulative Non-Convertible Redeemable preference shares to its holding company, Sahara India Commercial Corporation Limited at an issued price of Rs. 500/- (including face value of Rs. 10/-. and premium of Rs. 490). The complete board resolution in respect of the said issue is enclosed herewith as Annexure 1. your goodself has sought the basis for arriving at the premium allotment for the shares. AR submitted that valuation of preference shares should be made on the basis of returns received by the investor from such instruments. It was submitted that investor shall receive Rs. 750 per share after expiry of five years period, which would give a return of approximately 10 % per annum. Accordingly, it was submitted that premium of Rs. 490/- is justified. Accordingly, the Assessing Officer arrived at fair market value of the shares at Rs. 38/- per share. Accordingly, the Assessing Officer took the view that reasonable premium should have been Rs. 28/- per share. Accordingly, Assessing Officer took the view that excess premium of Rs. 462/- per share which worked out to Rs. 28.22 crores is not satisfactory and accordingly assessed the same as income of the assessee. here is no justification in assessing the alleged excess premium as income of the assessee. Accordingly we are of the view that the Ld CIT(A) was justified in deleting the impugned addition and accordingly we uphold his decision. In the result, the appeal filed by the revenue is dismissed.