Valuation for income-tax clearance depends on the specific interest transferred, not the whole property, under registration rules.

For the purposes of section 230A of the Income-tax Act and rule 30(iii) of the Kerala Registration Rules, the relevant valuation is that of the specific right, title or interest proposed to be transferred, not the entire property. Where only an undivided share is conveyed and its value is below the prescribed ceiling, an income-tax clearance certificate is not required. Any departmental circular or clarification inconsistent with the statutory language cannot override that plain rule. On that basis, insistence on a clearance certificate and refusal to register the document were described as without jurisdiction.

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Issues: Whether, for the purpose of section 230A of the Income-tax Act and rule 30(iii) of the Kerala Registration Rules, the relevant value is the value of the entire property or only the value of the undivided interest sought to be transferred, and whether insistence on an income-tax clearance certificate was justified.

Analysis: Section 230A and rule 30(iii) apply only where the right, title or interest sought to be transferred is in property valued above the prescribed limit. The statutory language makes the transferor's interest the relevant criterion, not the value of the entire property. Since only the petitioner's undivided share was proposed to be conveyed and its value was below the ceiling, the document did not attract the requirement of an income-tax clearance certificate. A departmental circular or clarification contrary to the statutory mandate could not control the plain meaning of the provision.

Conclusion: The insistence on an income-tax clearance certificate was illegal, and the refusal to register the document was without jurisdiction.

Final Conclusion: The document was directed to be registered without insisting on income-tax clearance because the valuation test had to be applied to the specific share transferred, not to the entirety of the property.

Ratio Decidendi: For the purpose of section 230A of the Income-tax Act and the corresponding registration rule, the decisive factor is the value of the specific right, title or interest sought to be transferred, and not the value of the whole property.

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