Valuer registration requires prescribed qualifications; institutional membership alone is insufficient unless based on passed examinations.

Registration as a valuer under the Wealth-tax framework depended on satisfying the qualifications prescribed under section 34AB and Rule 8A. For immovable property, the rule required a relevant graduate qualification in civil engineering, architecture or town planning, or another qualification recognised by the Central Government for superior posts in the relevant field. Institutional membership could not be treated as the required qualification unless it was granted on the basis of passing the institution's examinations. A person holding electrical engineering qualifications and civil engineering membership of the Institution of Engineers (India) without passing its examination did not meet the prescribed criteria and was therefore not entitled to registration as a valuer.

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Issues: Whether a person qualified in electrical engineering, and holding membership of the Institution of Engineers (India) in civil engineering without having passed the institution's examination, was entitled to registration as a valuer under the Wealth-tax Act.

Analysis: Registration as a valuer was available only to a person possessing the qualifications prescribed under section 34AB and Rule 8A of the Wealth-tax Rules. For immovable property, the rule required, among other alternatives, a graduate qualification in civil engineering, architecture or town planning, or a qualification recognised by the Central Government for recruitment to superior services or posts under the Central Government in the relevant field. Explanation 2 to Rule 8A excluded institutional membership from being treated as a requisite qualification unless the membership had been granted on the basis of passing the examinations conducted by the institution. The petitioner's membership was obtained without passing any such examination.

Conclusion: The petitioner was not qualified for registration as a valuer and was not entitled to relief.

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