The assessee, on March 2, 1993, gifted 29,46,500 shares and 69,49,900 shares, respectively, in two public limited companies of its group, both listed and quoted on the stock exchange. The shares had been allotted to the assessee on November 17, 1990 and July 10, 1991, and were under a lock-in period up to November 16, 1993 and May 25, 1994, respectively. The Gift-tax Officer held  that there was a deemed gift under section 4(1)(a) and (b) of the Act to the extent of Rs. 69,78,49,800 and levied gift-tax with interest quantified at Rs. 54,01,12,525. On appeal the Commissioner (Appeals) ordered tax at Rs. 5.06 crores plus interest at Rs. 7.99 crores. The Tribunal enhanced the tax to Rs. 43.25 crores. On further appeal the High Court held the certificate issued by the stock exchange was conclusive, that there was a lock-in period, that just because the shares were quoted in the stock exchange, that by itself would not mean that some value could be attached, and the value would be so available only if the shares were traded, and that the Commissioner (Appeals)’s valuation was acceptable. On appeal to the Supreme Court affirming  the decision of the High Court held that  although the companies listed  the valuation to be according to Schedule III to wealth-Tax Act, 1957 taking restrictions on transfer in to account.     (AY.1993-94)