Arbitration Involving Business Valuation Discrepancy Claims

Business valuation discrepancy disputes arise when parties disagree about the value of a company, business undertaking, shares, partnership interest, intellectual property, assets, or an enterprise as a whole, particularly where a contract provides for a valuation-based payment or exit.

These disputes commonly arise in:

shareholder agreements;

joint ventures;

private-equity investments;

mergers and acquisitions;

put/call options;

compulsory buy-outs;

minority exits;

earn-outs;

deferred consideration;

purchase-price adjustments;

deadlock arrangements;

employee share schemes;

partnership dissolutions; and

oppression/mismanagement settlements.

The central arbitration question is usually not simply “What is the business worth?” It is:

What valuation methodology did the parties contractually agree upon, what was the correct valuation date, what assumptions should be used, and has the valuer or arbitral tribunal correctly applied the contractual mechanism?

A particularly important Indian authority is Bajaj Auto Ltd. v. Western Maharashtra Development Corporation Ltd., where an arbitral award specifically determined the value of a substantial shareholding and the Bombay High Court examined challenges concerning the valuation methodology, discounts and reasoning. (Indian Kanoon)

1. Nature of a Business Valuation Dispute

Assume that a shareholders' agreement provides:

“Upon exit, the shares shall be purchased at fair market value as determined by an independent valuer.”

The shareholder's expert values the company at:

₹1,000 crore

The company's expert values it at:

₹650 crore

The difference is:

₹350 crore.

The disagreement may result from different assumptions concerning:

future revenue;

EBITDA;

growth;

debt;

working capital;

goodwill;

intangible assets;

market multiples;

discount rates;

minority discount;

control premium;

liquidity discount;

contingent liabilities;

tax;

capital expenditure;

terminal value.

The arbitration therefore becomes both a contractual interpretation dispute and a valuation dispute.

2. Common Contractual Valuation Mechanisms

Business agreements commonly use one of four approaches.

A. Fixed formula

Example:

Purchase price = 7 × EBITDA.

B. Independent expert valuation

The parties appoint an independent valuer.

C. Fair-market-value mechanism

The agreement requires determination of the market value of the shares/business.

D. Accounting adjustment

The price is adjusted according to:

net debt;

working capital;

cash;

inventory;

liabilities;

EBITDA;

specified accounting standards.

The distinction matters because an arbitrator cannot ordinarily replace an agreed contractual formula merely because another methodology appears economically preferable.

3. Case Law 1 — Bajaj Auto Ltd. v. Western Maharashtra Development Corporation Ltd.

This is one of the strongest Indian authorities for arbitration involving share valuation.

The dispute concerned the sale of approximately 27% of Maharashtra Scooters Ltd. held by Western Maharashtra Development Corporation to Bajaj Auto.

An arbitrator determined the shares' value at ₹151.63 per share as of 3 May 2003. The valuation involved questions concerning:

valuation date;

quoted investments;

discounts;

net asset value;

market value;

treatment of investments; and

expert valuation evidence. (Indian Kanoon)

Importance

The case demonstrates that valuation disputes can be genuine questions of expert judgment rather than matters capable of being resolved by simply looking at a company's balance sheet.

The challenge to the award also illustrates an important arbitration principle:

A court reviewing an arbitral valuation award does not ordinarily conduct a fresh valuation merely because another valuation methodology might produce a different result.

Practical lesson

A valuation award should explain:

why the chosen methodology was appropriate;

why the valuation date was selected;

why discounts/premiums were applied;

how expert evidence was treated.

An unexplained figure is significantly more vulnerable than a reasoned valuation.

4. Case Law 2 — Pushpa P. Mulchandani v. Admiral Radhakrishin Tahiliani

This Bombay High Court decision concerned an arbitral award involving valuation of business divisions and shares.

The parties challenged the award partly because valuation reports relied upon by the arbitrator had allegedly not been supplied to them. The court considered whether the absence of the valuation reports undermined the arbitral process. (Casemine)

Legal significance

The case demonstrates the importance of procedural fairness in valuation arbitration.

A party should ordinarily have a meaningful opportunity to:

examine the valuation methodology;

review the underlying valuation report;

challenge assumptions;

cross-examine the expert where appropriate;

provide its own valuation evidence.

Application

If the arbitrator simply states:

“I accept the valuer's figure of ₹800 crore,”

without giving the affected party an adequate opportunity to challenge the valuation material, the award may become vulnerable depending on the applicable procedural law.

5. Case Law 3 — Satco Capital Markets Ltd. v. Rahul H. Bajaj

This litigation arose out of an arbitration concerning the purchase/sale of shares and subsequent valuation consequences.

A major issue was which date should be used for determining the value of the shares.

The dispute became particularly significant because the value of the shares had increased dramatically during the long period between the original dispute and subsequent proceedings. The Bombay High Court examined whether valuation should be based on the original transaction period or a much later market value. (Indian Kanoon)

Principle

The valuation date is not a minor technicality.

It can radically change the amount payable.

For example:

Company value in 2018: ₹500 crore

Company value in 2026: ₹2,000 crore

If the contractual valuation date is 2018, a claimant cannot necessarily demand the 2026 value simply because arbitration took eight years.

Practical lesson

Every valuation arbitration should identify:

What is the legally relevant valuation date?

6. Case Law 4 — Rahul Bajaj v. Mangal Keshav Securities Ltd.

The Bombay High Court dealt with an arbitral award involving obligations concerning shares and the financial consequences of delayed implementation.

The case demonstrates the distinction between:

the value applicable at the relevant contractual/transactional time; and

the market value existing when the dispute is finally resolved. (Indian Kanoon)

Importance

A party cannot automatically convert a historical contractual entitlement into a claim based on the current market price merely because the dispute took years to resolve.

Valuation principle

The tribunal must identify the legal event that triggers valuation:

breach;

exercise of option;

notice of exit;

termination;

closing;

valuation date;

award date.

7. Case Law 5 — J.P. Srivastava & Sons (Rampur) Pvt. Ltd. v. Gwalior Sugar Co. Ltd.

This Company Law Board decision involved an agreement under which shares were to be sold based on a valuation determined by an independent chartered accountant.

The parties had agreed that the valuer's determination would be binding. The valuer was instructed to consider the family nature of the company and the circumstances of the shareholder's exit. (Indian Kanoon)

Significance

This case demonstrates the importance of the valuation mandate.

A valuer should not merely receive the instruction:

“Value the company.”

The agreement should specify factors such as:

control;

minority status;

marketability;

family-company characteristics;

assets;

liabilities;

earnings;

future prospects.

Arbitration application

If parties agree that an expert's determination is final and binding, the subsequent dispute may concern:

Did the expert act within the contractual mandate?

That is different from simply asking whether the expert's conclusion was numerically correct.

8. Case Law 6 — R. Sivakumar v. SRP Tools Ltd.

The Madras High Court discussed principles concerning share valuation and referred to the Supreme Court's observation that valuation of shares is a technical matter requiring considerable skill and experience.

The court also discussed the use of recognized valuation approaches and rejected the proposition that every valuation disagreement automatically requires a second independent valuation. (Indian Kanoon)

Importance

This supports an important proposition:

Valuation is an expert exercise, not necessarily a mathematical exercise producing one indisputably correct number.

Different competent valuers may reasonably reach different figures because they use different assumptions.

Therefore, the tribunal should ask:

Was the methodology appropriate?

Were the assumptions supported?

Was the valuer's mandate followed?

Was relevant information considered?

Was the result internally consistent?

rather than simply:

“Could another expert have produced a different number?”

9. Case Law 7 — Shri Mihir Chakraborty v. Muti Tech Computers Pvt. Ltd.

The Calcutta High Court considered a valuation report concerning a shareholder's stake in a private company.

The valuation had been performed by professional valuers, and the court considered whether the valuation should be treated as binding and what the appropriate legal remedy was against the valuation process. (Indian Kanoon)

Importance

The case highlights the distinction between:

Valuer acting as an expert

and

Valuer acting as an arbitrator.

This distinction is extremely important.

If the contract says:

“An independent expert shall determine the value,”

the expert's determination may be governed by contractual expert-determination principles.

If the person is expressly appointed as:

“Arbitrator,”

the Arbitration Act's procedural and judicial-review framework becomes relevant.

10. Case Law 8 — RMP Seller Holdings, LLC v. SM Buyer LLC

This is a particularly significant recent M&A arbitration involving a post-closing financial adjustment.

The transaction concerned Save Mart and its interest in Super Store Industries. The arbitrator had to determine the treatment of approximately $109 million of SSI debt under the parties' purchase agreement.

The arbitrator's interpretation resulted in a very large post-closing payment obligation against the seller. The Delaware Court of Chancery confirmed the award, and the Delaware Supreme Court affirmed the judgment in November 2024. (Justia Law)

Why this matters for valuation disputes

Although technically framed as a purchase-price adjustment/accounting dispute, it is highly relevant to business valuation arbitration.

The fundamental lesson is:

The contractual definitions control the economic calculation.

The arbitration involved questions concerning:

purchase price;

indebtedness;

accounting methodology;

equity value;

treatment of debt;

post-closing adjustment.

The reviewing court emphasized the narrow scope of judicial review of an arbitral award. (Business Law Today from ABA)

Practical lesson

If an SPA says:

“Indebtedness shall include X, Y and Z,”

the tribunal may enforce those definitions even where the resulting economic outcome appears surprising.

Therefore:

Contract drafting is itself a valuation-control mechanism.

11. Case Law 9 — Ganz v. Petronz FZE

This English Commercial Court decision involved a share purchase agreement concerning shares in a company and an LCIA arbitration clause.

The dispute demonstrates the importance of establishing:

the validity of the SPA;

parties bound by the arbitration agreement;

the scope of the arbitration;

contractual rights concerning shares. (BAILII)

Relevance

Business valuation disputes frequently arise alongside disputes about:

whether a share sale occurred;

whether an option was exercised;

whether a purchase price became payable;

whether the correct number of shares was transferred.

The tribunal therefore may need to determine both entitlement and valuation.

12. Core Valuation Methodologies

A. Discounted Cash Flow — DCF

The company is valued according to the present value of expected future cash flows.

Simplified:

Enterprise Value = Present Value of Future Cash Flows + Terminal Value

DCF disputes often concern:

revenue projections;

EBITDA margins;

capital expenditure;

working capital;

tax;

discount rate;

terminal growth.

Example

Expert A:

DCF value = ₹900 crore

Expert B:

DCF value = ₹600 crore

The difference may result largely from the discount rate.

13. Discount Rate Disputes

Suppose projected annual cash flows are identical.

Expert A uses:

WACC = 9%

Expert B uses:

WACC = 13%

The resulting valuations may differ substantially.

The tribunal should require evidence concerning:

risk-free rate;

equity-risk premium;

beta;

cost of debt;

capital structure;

country risk;

company-specific risk.

A valuation cannot simply select a discount rate because it produces a preferred result.

14. Comparable Company Method

The valuer compares the business with similar listed or private companies.

Common multiples include:

EV/EBITDA;

EV/Revenue;

P/E;

EV/EBIT;

Price/Book.

Problem

No two companies are identical.

Therefore adjustments may be required for:

size;

growth;

margins;

geography;

leverage;

liquidity;

business model.

15. Precedent Transaction Method

The valuer examines comparable acquisitions.

For example:

Company A acquired at 8× EBITDA;

Company B acquired at 10× EBITDA;

Target company EBITDA = ₹50 crore.

A valuation might fall around:

₹400–₹500 crore

But the tribunal must consider:

control premium;

strategic buyer;

market conditions;

transaction date;

synergies.

16. Net Asset Value

NAV is particularly important for:

investment companies;

holding companies;

real estate businesses;

asset-heavy businesses.

Simplified:

NAV = Fair Value of Assets − Liabilities

But valuation disputes arise over whether assets should be valued at:

book value;

market value;

liquidation value;

replacement value.

Bajaj Auto v. Western Maharashtra Development Corporation illustrates the importance of methodology and discounts when valuing a holding company/shareholding.

17. Market Capitalization

For listed businesses:

Share Price × Number of Shares

may provide a market-based indication.

But disputes can arise concerning:

valuation date;

market volatility;

thin trading;

block size;

control premium;

marketability.

A 30% block may not necessarily be valued by simply multiplying the latest quoted price by the number of shares.

18. Minority Discount

Suppose:

100% company value = ₹1,000 crore.

A shareholder owns:

10%.

A simple calculation gives:

₹100 crore.

But the company argues:

“The 10% stake lacks control and should receive a minority discount.”

The shareholder responds:

“The shareholders' agreement requires fair value without a minority discount.”

This is a contractual question before it becomes a valuation question.

19. Control Premium

Conversely, a controlling shareholder may argue that its stake deserves a premium.

Example:

Standalone share value = ₹100

Control premium = 20%

Control value = ₹120

Whether that premium applies depends on:

valuation standard;

contractual language;

purpose of valuation;

legal framework.

20. Illiquidity / Marketability Discount

Private-company shares may be difficult to sell.

A valuer might therefore apply a:

Discount for Lack of Marketability (DLOM).

But parties may dispute:

whether the discount is appropriate;

percentage;

empirical basis;

whether the shareholder agreement already accounts for illiquidity.

21. Valuation Date

This is often the most important preliminary issue.

Possible dates include:

Contract date

When the agreement was signed.

Breach date

When contractual breach occurred.

Exit date

When the shareholder exercised an exit right.

Closing date

When the acquisition closed.

Valuation notice date

When the valuation mechanism was triggered.

Award date

When the arbitrator makes the decision.

The tribunal should not select the date merely because it produces the fairest economic outcome.

It should identify the date required by the contract and applicable law.

22. Earn-Out Disputes

A business may be sold for:

₹500 crore upfront + ₹200 crore earn-out.

The earn-out depends upon:

EBITDA exceeding ₹100 crore.

The buyer calculates:

EBITDA = ₹90 crore

The seller calculates:

EBITDA = ₹120 crore

The resulting dispute may involve:

revenue recognition;

accounting policies;

allocation of corporate costs;

extraordinary expenses;

management fees;

related-party transactions.

This is essentially a valuation dispute even though it may be described as an earn-out dispute.

23. Purchase-Price Adjustment Disputes

A typical SPA might state:

Base Purchase Price = ₹500 crore

Then:

+ Cash

− Debt

± Working Capital Adjustment

The parties later disagree.

Buyer:

Debt = ₹150 crore.

Seller:

Debt = ₹90 crore.

The difference is ₹60 crore.

The arbitration will often focus more on contractual accounting definitions than on conventional business valuation.

The RMP Seller Holdings v. SM Buyer litigation demonstrates how a post-closing adjustment can produce an extraordinarily large economic consequence where contractual definitions and accounting treatment differ. (Justia Law)

24. Goodwill

Goodwill can be particularly controversial.

The buyer may say:

“Goodwill is already included in enterprise value.”

The seller may argue:

“Separately acquired goodwill should be valued.”

The tribunal must avoid double counting.

25. Intangible Assets

Valuation disputes may concern:

patents;

trademarks;

software;

customer relationships;

databases;

licences;

brand value;

proprietary technology.

The valuation may require specialist evidence.

26. Contingent Liabilities

Suppose the company faces:

₹200 crore litigation exposure.

Expert A applies a 20% probability:

₹40 crore expected liability.

Expert B applies 70%:

₹140 crore expected liability.

That difference directly affects equity value.

The tribunal should require evidence regarding:

probability;

quantum;

legal advice;

historical outcomes;

insurance;

indemnities.

27. Information Asymmetry

One party often controls the company's information.

The buyer may possess:

management accounts;

forecasts;

customer data;

budgets.

The seller may possess:

historical records;

private contracts;

contingent liabilities.

This can create discovery disputes.

The tribunal may need to order production of:

management accounts;

budgets;

forecasts;

board minutes;

investment memoranda;

financial models;

customer contracts.

28. Expert Evidence

Valuation arbitration is heavily dependent on expert evidence.

The ideal expert report should explain:

valuation date;

valuation standard;

methodology;

assumptions;

source data;

calculations;

adjustments;

sensitivity analysis;

alternative scenarios;

conclusion.

A tribunal should be cautious about expert reports that simply present a number without explaining the assumptions behind it.

29. Expert Determination vs Arbitration

This distinction is fundamental.

Expert determination

The expert determines a technical issue.

Example:

“Determine EBITDA according to the agreed accounting principles.”

Arbitration

The arbitrator determines legal disputes.

Example:

“Was the seller entitled to exercise the put option?”

Hybrid

A contract may say:

“Valuation shall be determined by an independent expert, whose determination shall be final except for manifest error, and all other disputes shall be arbitrated.”

That structure can substantially reduce the tribunal's role in recalculating the valuation.

30. When Can an Arbitrator Reject a Valuer's Determination?

Possible grounds include:

valuer exceeded contractual mandate;

wrong valuation date;

wrong methodology required by contract;

mathematical error;

failure to consider mandatory information;

bad faith;

manifest error;

procedural unfairness;

conflict of interest;

failure to follow contractual accounting principles.

A mere disagreement between experts is generally not enough.

31. Judicial Review of Valuation Awards

Under Indian arbitration law, a court reviewing an award under Section 34 of the Arbitration and Conciliation Act, 1996 does not ordinarily sit as a valuation appellate court.

The key question is whether the award falls within recognized grounds for setting aside.

Therefore:

“My expert would have valued the company at ₹900 crore rather than ₹700 crore”

does not automatically establish a Section 34 ground.

The court generally will not conduct a complete rehearing of the valuation evidence.

32. Reasoned Award Requirement

A valuation award should explain:

why one expert was preferred;

why certain assumptions were accepted;

why a discount was applied;

why another discount was rejected;

why the selected valuation date applies.

This is particularly important in light of the reasoning issues examined in Bajaj Auto v. Western Maharashtra Development Corporation.

An unexplained conclusion such as:

“₹750 crore is fair and reasonable”

may be vulnerable if the tribunal was required to give reasons.

33. Contractual Accounting Standards

M&A agreements frequently specify:

Indian GAAP;

Ind AS;

IFRS;

US GAAP;

historical accounting practices.

A valuation dispute may therefore actually be an accounting interpretation dispute.

The tribunal must first ask:

What accounting rules did the parties contractually select?

Only then should it calculate the adjustment.

34. The Save Mart Lesson

The RMP Seller Holdings v. SM Buyer dispute provides an especially powerful practical lesson.

The seller argued that the arbitrator's interpretation produced an economically irrational result. Nevertheless, the Delaware courts maintained a highly deferential approach to the arbitral award, and the Delaware Supreme Court ultimately affirmed the judgment. (Justia Law)

The message for drafting is clear:

Do not assume that an arbitrator or reviewing court will correct a commercially undesirable valuation formula merely because the economic result appears unreasonable.

The parties should therefore define:

debt;

cash;

working capital;

enterprise value;

equity value;

excluded liabilities;

transaction expenses;

accounting principles;

treatment of minority interests.

35. Fraudulent or Manipulated Valuation

More serious disputes may involve allegations that management deliberately manipulated:

EBITDA;

revenue;

expenses;

inventory;

debt;

working capital;

forecasts.

For example:

Seller artificially increases EBITDA by ₹20 crore immediately before valuation.

The buyer may allege:

fraud;

misrepresentation;

breach of warranty;

breach of fiduciary duty.

The tribunal must distinguish legitimate valuation assumptions from intentional manipulation.

36. Valuation and Fraud

If the contract contains an arbitration clause, fraud allegations do not automatically make the dispute non-arbitrable.

The tribunal may have jurisdiction over contractual fraud claims depending upon:

wording of arbitration clause;

governing law;

applicable arbitration statute.

However, allegations of fraud can increase the evidentiary burden and may require extensive document production.

37. Minority Shareholder Valuation

A minority shareholder's exit claim frequently raises the question:

Should the shareholder receive proportionate enterprise value or fair value without discounts?

For example:

Company value:

₹1,000 crore

Shareholding:

20%

Simple pro-rata value:

₹200 crore

But if a 25% minority discount is applied:

₹150 crore

The difference is:

₹50 crore.

The tribunal should not apply the discount automatically. The answer depends upon:

contract;

valuation standard;

governing corporate law;

purpose of valuation;

rights attached to shares.

38. Deadlock Valuation

A shareholders' agreement may provide:

If shareholders cannot agree, one shareholder may buy the other's shares at fair market value.

Deadlock may therefore trigger:

valuation;

buy-out;

arbitration.

The tribunal may need to determine:

whether a deadlock actually occurred;

whether the exit right was validly exercised;

valuation date;

value of shares;

whether minority discount applies.

39. Private Equity Exit Disputes

Private-equity agreements may contain:

put options;

call options;

tag-along rights;

drag-along rights;

IPO exit provisions;

guaranteed returns;

valuation formulas.

Disputes can arise when the investor's exit price is significantly different from management's valuation.

A tribunal may have to distinguish:

Contractual return mechanism

from

Fair market value mechanism.

40. Damages for Wrongful Valuation

Suppose the correct valuation is:

₹1,000 crore

but the contractually determined valuation was:

₹700 crore.

A shareholder holding 30% suffers a potential difference of:

₹90 crore.

But damages may depend upon:

whether the valuation itself is the contractual price;

whether the valuer's decision is final;

whether there was fraud;

whether the claimant accepted the valuation;

whether the claim is for damages or specific performance.

41. Limitation

Valuation disputes can involve long periods.

The tribunal must consider when the cause of action arose:

signing of agreement;

valuation notice;

delivery of valuation report;

rejection of valuation;

closing;

payment date;

discovery of error.

The contractual dispute-resolution clause may also contain procedural deadlines.

42. Confidentiality

Business valuation disputes often involve highly sensitive information:

revenue;

margins;

customer contracts;

acquisition plans;

intellectual property;

strategic forecasts.

Arbitration can therefore be attractive because it can provide greater procedural privacy than ordinary public litigation, subject to the applicable law and institutional rules.

43. Recommended Arbitral Approach

A tribunal should generally proceed in the following order:

Step 1 — Identify the contract

What agreement creates the valuation right?

Step 2 — Identify the valuation event

What triggered valuation?

Step 3 — Determine valuation date

Which date applies?

Step 4 — Determine valuation standard

Is it:

fair market value?

fair value?

enterprise value?

equity value?

net asset value?

Step 5 — Identify mandatory methodology

Does the contract require:

DCF?

EBITDA multiple?

NAV?

independent expert?

accounting formula?

Step 6 — Examine expert evidence

Compare assumptions.

Step 7 — Resolve legal issues

Determine:

discounts;

premiums;

contractual adjustments;

accounting rules.

Step 8 — Calculate

Apply the agreed methodology.

Step 9 — Give reasons

Explain the calculation sufficiently to permit meaningful review.

44. Key Issues the Tribunal Should Determine

A comprehensive valuation arbitration should address:

What asset/business is being valued?

What percentage interest is being valued?

What is the valuation date?

What valuation standard applies?

What methodology applies?

What financial statements should be used?

What treatment applies to debt?

What treatment applies to cash?

What working-capital adjustment applies?

Are contingent liabilities deducted?

Should minority discount apply?

Should a control premium apply?

Should a marketability discount apply?

How should goodwill be valued?

How should intangible assets be treated?

How should future growth be projected?

What discount rate is appropriate?

What terminal growth rate is appropriate?

Which comparable companies are relevant?

Is the valuer's report contractually binding?

Has the valuer exceeded its mandate?

Was the valuation process procedurally fair?

Did either party manipulate financial information?

What damages or purchase price adjustment follows?

45. Comparative Case-Law Table

46. Most Important Legal Principles

Principle 1 — Contract first, valuation second

The tribunal must first determine what the parties agreed to value and how they agreed to value it.

Principle 2 — Valuation date is fundamental

A valuation performed on the wrong date may produce a perfectly calculated but legally incorrect result.

Principle 3 — Different valuations do not necessarily mean one is negligent

Business valuation contains legitimate professional judgment.

Principle 4 — Experts must remain within their mandate

A valuer cannot rewrite the parties' agreement.

Principle 5 — Discounts and premiums require justification

Minority discounts, control premiums and marketability discounts should be based on the applicable valuation standard and contractual terms.

Principle 6 — Accounting definitions can determine economic outcomes

The RMP Seller Holdings dispute demonstrates how contractual accounting definitions can have enormous financial consequences. (Justia Law)

Principle 7 — Courts generally do not revalue the business

An unsuccessful party ordinarily cannot convert a Section 34 challenge into a fresh valuation exercise.

Principle 8 — Reasons matter

A tribunal should demonstrate how it moved from the evidence to the final valuation.

47. Conclusion

Business valuation discrepancy arbitration sits at the intersection of contract law, company law, accounting, finance, valuation science and arbitration law.

The central dispute can be represented as:

Contract

↓

Valuation trigger

↓

Valuation date

↓

Valuation standard

↓

Methodology

↓

Financial assumptions

↓

Expert evidence

↓

Adjustments

↓

Final business/equity value

↓

Arbitral award

The Indian decision in Bajaj Auto Ltd. v. Western Maharashtra Development Corporation Ltd. is particularly instructive because it involved an actual arbitral determination of share value and challenges to the valuation methodology. (Indian Kanoon) The Pushpa Mulchandani decision emphasizes the procedural importance of valuation reports and the parties' opportunity to address valuation evidence. (Casemine) The Satco Capital Markets litigation demonstrates why the valuation date can become the decisive issue when a dispute remains unresolved for many years. (Indian Kanoon)