Quoted share valuation turns on the latest available market quotation near the valuation date, with the Bombay Stock Exchange rate accepted.

For valuation of quoted shares, the quotation nearest to the valuation date was the proper basis, and the later Bombay Stock Exchange quotation was preferred over the Delhi Stock Exchange quotation because it reflected a more recent transaction. The revenue did not show any still-closer higher transaction price. On that basis, the Bombay Stock Exchange quotation was correctly accepted for valuation and the revenue's challenge failed.

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Issues: Whether, for valuation of quoted shares held by the assessee, the quotation of the Bombay Stock Exchange or the Delhi Stock Exchange should be adopted.

Analysis: The shares were quoted on both exchanges, but the Bombay Stock Exchange quotation was based on a later transaction date closer to the valuation date than the Delhi Stock Exchange quotation. The revenue did not establish that any higher transaction existed on a still closer date. In these circumstances, the quotation reflecting the latest available transaction near the valuation date was the proper basis for valuation.

Conclusion: The Bombay Stock Exchange quotation was rightly accepted and the revenue's challenge failed.

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