In Brief
BPL Limited gifted shares in two subsidiaries to Celestial Finance in 1993. The shares, though held in listed companies, were subject to lock-in periods preventing sale. The Revenue argued they should be valued at quoted market prices; BPL contended they were unquoted given transfer restrictions. The Supreme Court held that shares in lock-in cannot be \"quoted shares\" under tax law because they lack regular exchange quotations and current transactions. Such shares must be valued under the unquoted share formula. Market restrictions materially affect value and must be reflected in valuation; hybrid methods applying quoted-share formulas with arbitrary depreciation are impermissible. The Revenue's appeal was dismissed.",
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