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Assumptions and Sensitivity Analysis in a Valuation Report

A valuation resting on undisclosed assumptions is legally defective. How to state assumptions, build them where data is missing, and present sensitivity the CoC can...

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IBC Insolvency
Published
September 5, 2026
Last updated
Sep 30, 2026
Reading time
8 min
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Last updated: September 2026Verified against: Government sources

Every valuation rests on assumptions. That is not a weakness; it is what valuation is.

The defect is not making assumptions. It is not saying so — because an assumption nobody can see is an assumption nobody can test, and a number nobody can test cannot support a decision about other people's money.

The format is no longer yours to choose

Until the February 2026 reforms, how a valuation report was laid out was largely the valuer's decision, and disclosure quality varied enormously between reports on the same debtor.

Three changes closed that off:

A standardised reporting format per asset class. Land and Building, Plant and Machinery and Securities or Financial Assets each have a prescribed structure. The assumptions section is part of it, which means "we did not have a section for that" stopped being an available explanation.

IVS only, from 1 April 2026. The earlier latitude to work to an RVO's own standard or another recognised framework has gone. Assumption disclosure and the basis of value are governed by IVS, not by house style. IVS for IBC valuations →

A VRIN on every page. The Valuation Report Identification Number is generated on the IBBI portal, sits in the left-hand footer of every page, and is dated to issue — so the version of the report containing a given set of assumptions is identifiable. VRN, VRIN and liability →

The practical effect on assumptions is straightforward. A prescribed structure makes an omission visible. Where a section exists and is empty, that is a finding on the face of the report rather than something an objector has to reconstruct.

ESG belongs in the assumptions now

The 2025 IVS update brought ESG factors into the valuation exercise, and the February 2026 framework made their consideration mandatory in IBC valuations.

In a distressed manufacturing debtor this is rarely abstract. The items that actually move numbers:

  • Environmental remediation liabilities — contaminated land, effluent treatment obligations, accumulated hazardous waste. These reduce realisable value and are frequently undisclosed by the debtor.
  • Consent and compliance status — a plant operating without a valid pollution control consent, or with a closure direction outstanding, is not the plant the register describes.
  • Employment and social obligations — the settlement expected before a workforce releases a site is a real cost against the estate. When workers block access →
  • Transition risk — an asset viable today and stranded by a regulatory or technology shift within the plan period.

Where an ESG factor is material, it belongs in the stated assumptions and, if it drives the answer, in the sensitivity analysis. Where it was considered and found immaterial, say that — a report silent on ESG now reads as a report that did not look.

Where assumptions come from in a distressed company

In a solvent business you assume relatively little — the data exists. In a CIRP, whole categories are missing:

  • the business stopped trading years ago, so there are no current forecasts;
  • management has left, so nobody can explain the numbers that do exist;
  • records are seized or inaccessible; Valuing when records are seized →
  • statutory demands are disputed with no resolution in sight;
  • encumbrances may exist that nobody has disclosed.

So assumptions do more work here than in almost any other valuation context — which is precisely why the disclosure obligation is stricter.

How to build an assumption when there is no data

Not by guessing, and not by leaving the item out. By constructing it visibly:

Industry benchmarks. Sector recovery rates, comparable royalty ranges, typical completion costs per square foot, standard plant refurbishment costs.

Historical filings and regulatory submissions. Even a company with no accessible books has filed returns, and those filings are a source.

Third-party and creditor records. Bank statements held by lenders, GST returns, customer and supplier confirmations.

Professional judgment, labelled as such. A legitimate input — provided the report says "this is a judgment, here is the reasoning" rather than presenting it as though it were observed data.

Then the rule that makes all of it defensible: every such assumption is stated and justified in the report. Judicial scrutiny →

What sensitivity analysis is for

Not decoration. It answers the only question a CoC member genuinely needs answered about a number they cannot verify: how wrong could this be, and what would make it wrong?

A useful sensitivity presentation:

  • identifies the two or three assumptions that actually drive the answer — not all twenty;
  • shows the value at a low, central and high setting for each;
  • flags where a small change produces a large swing, because that is where the risk sits;
  • gives a range with the drivers named, rather than a point estimate.

"₹40–55 crore, driven mainly by the royalty rate and the assumed completion timeline" tells the CoC far more than "₹47 crore" — and it is a far better position to be in when the number is challenged.

Where a probability can be attached — disputed statutory demands are the standard case — a probability-weighted range is better still. Statutory liabilities →

The assumptions that most need stating

Because they are the ones most often left implicit:

AssumptionWhy it matters
Basis of value and valuation dateDifferent bases give different answers; the date is the insolvency commencement date
Going concern or realisableThe single biggest driver in a shut-down debtor →
Completion cost and timelineDecides whether a real estate project has positive value at all
Recovery probability on receivablesBook balance is not a value
Treatment of disputed demandsExcluded, included, or ranged — say which
Encumbrances assumed absentIf you did not verify, say you did not
Assets not physically verifiedName them and state the effect
ESG factorsRemediation liabilities, consent status, transition risk — mandatory since the 2025 IVS update
Forecast revenueEspecially where the historical line is not the base case

The failure mode

A report that reads confidently, produces a single number, and does not disclose that the number assumed a two-year completion timeline when four is equally plausible.

When the challenge comes, the valuer explains the assumption for the first time in the hearing. At that point it looks like a rationalisation rather than a method — and the CoC decision built on the number is exposed, whether or not the assumption was sound.

Disclose it in the report and it is analysis. Disclose it under cross-examination and it is a problem.

Key takeaways

  • Making assumptions is not the defect. Hiding them is.
  • The format is prescribed — an empty section is now a visible finding.
  • ESG factors are mandatory, and remediation liabilities are usually undisclosed.
  • List them in one place, not scattered through the narrative.
  • Build missing data from benchmarks and filings, and say so.
  • Label professional judgment as judgment.
  • Sensitivity on the two or three drivers, not all of them.
  • Give a range with the drivers named.
  • State which assets were not verified and what that does to the number.

Read next

Disclaimer: Positions stated as on 5 September 2026. General guidance on reporting practice only.

Quick recapKey facts & short answers

Key Facts About Assumptions and Sensitivity Analysis

  • Applies in: All states across India, under the relevant central law.
  • Mode: Mostly online via the official government portal.
  • Typical timeline: Ranges from a few days to a few weeks depending on the case.
  • Non-compliance: May attract penalties, interest or late fees.
  • Expert help: TaxClue completes the entire process end to end for you.

Why must assumptions be disclosed in a valuation report?

Because an undisclosed assumption cannot be tested by the CoC or the Adjudicating Authority, which makes the valuation defective regardless of whether the assumption was reasonable.

What should a valuer do when data is unavailable?

Construct the assumption from industry benchmarks, historical filings, regulatory submissions and third-party records, and state explicitly that this is what was done.

Assumptions and Sensitivity Analysis: a key compliance topic in Indian tax and corporate law that businesses and individuals must understand to remain compliant.

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Questions, answered

Short, direct answers to the 8 questions readers ask most on this topic.

Because an undisclosed assumption cannot be tested by the CoC or the Adjudicating Authority, which makes the valuation defective regardless of whether the assumption was reasonable.

Construct the assumption from industry benchmarks, historical filings, regulatory submissions and third-party records, and state explicitly that this is what was done.

A presentation showing how the value moves as the key assumptions move, identifying the drivers and giving a range rather than a single figure.

The two or three that actually drive the answer. Sensitising everything obscures the ones that matter.

As a probability-weighted range, with the gross demand, its stage and the reasoning behind the probability all stated.

Yes. Since the February 2026 reforms a standardised reporting format applies per asset class, reports follow International Valuation Standards from 1 April 2026, and each carries a VRIN in the left-hand footer of every page.

Yes. Following the 2025 IVS update, ESG factors must be considered. Where material — remediation liabilities, consent status, transition risk — they belong in the stated assumptions and in the sensitivity analysis.

Yes, provided it is labelled as judgment and reasoned, rather than presented as observed data.