Request for Exemption of exam to Existing Govt. Reg. Valuers under Wealth tax Rules 34AB

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To,
Hon. Prime Minister
Govt. of India.
New Delhi.


Sub : Request for inclusion of existing and practicing Govt. Registered valuers under Section 34AB of wealth Tax Act 1957 as deemed qualified Registered Valuers under section 247 of Companies Act 2013. So, that there is no conflict in two regulations for same profession.

Respected Sir,
With most humble intentions, I submit following request for sympathetic consideration:

Request : Inclusion of following as an additional criteria for registration as valuer under Companies (Registered Valuers and valuation) Rules 2017.
“All the existing and practicing Registered valuers under 34 AB of Wealth Tax Act 1957 shall  be deemed eligible for Registration as Valuers under section 247 of Companies Act 2013 in their respective categories subject to membership of Registered Valuers Organization recognized under the Companies (Registered Valuers and valuation) Rules 2017 published on 18.10.2017 and subject to certificate of completion of prescribed training of 50 Hours by R.V. O, without appearing for examination which is mandatory for all registered valuers.”

Reasons :
• There are about 15,000 registered valuers under section 34 AB of Wealth Tax Act 1957(official figures from01.06.1981 to Feb 2011 was 9751), of which around 6,000 valuers are full time active in the profession of valuation. These registered valuers posses all the qualifications prescribed by Companies (Registered Valuers and valuation) Rules 2017. They possess more experience then prescribed by IBBI (Experience prescribed under section 34AB is 10 Years and experience prescribed by IBBI is 5 years) . There are laid down assessment criteria for registration of valuers under 34 AB of wealth tax act, seriously assessed by the officers of Income Tax authorities before issue of registration, but without examination. This has worked well all this long period of more than 50 years.
• The registered valuers under section 34 AB of wealth tax act have published more then 2000 research papers on valuation during last about 48 years in our journal Indian Valuer published monthly.
• All banking valuations are so far carried out by the Registered Valuers under section 34 AB of wealth tax act, rather most of the nationalized banks have precondition, that the applicant on the panel of Valuers should be Govt. Reg. valuer under Wealth Tax act, 1957.
• Net book value of NPAs of banks with respect to lending is much less then the gross book value of NPAs. Major part of lending is related to valuation is sound. There is no doubt on majority of the valuations carried out by registered valuers under section 34 AB of Wealth Tax Act 1957. The gross book value of NPAs is much more which is not directly related to valuation.
• There are about ten institutions promoted by registered valuer like Institution of
Valuers and others. These institutions organize seminars and workshops all over India through their branches spread nationwide to create an habit of learning and updating on case laws, changing business practices, changing market priorities and practices, convergence of global practices, more emphasis being given on Innovation, researchand out of box thinking.
• There has to be different criteria of assessment of professional competence for senior practicing professionals and for the new entrants. A common standard written exam and certification mandatory for all is oversimplification of assessment process which will reduce the profession to a very narrow, close and irrational standard. This is not in the interest of profession and must be recognition before damage is caused.
• New regulations are always welcome, we appreciate the dynamic nature of changing market realities to be recognized and necessary regulatory framework must be in place to meet the challenges of new situations. But it is also necessary that the right to earning of existing professionals are not harmed by new regulation. It has been a practice in India whenever a new regulation has been created, existing professionals are given their due place. New rules were formed for many other professionals too and simultaneously existing practitioners were given entry without any exam in following cases :
1. Licensing of Insurance Surveyors and Loss Assessors (Exhibit A).
2. Chartered Accountant Act 1949. (Exhibit B).
3. Company Secretaries Act 1980 (Exhibit C).
4. Architects Act 1972 (Exhibit D).
5. All India Bar Examination Rules, 2010 (Exhibit E).
I am submitting with very humble intentions that the valuers registered under
section 34 AB of wealth tax act are qualified, experienced professionals who
have been promoting valuation education, assisting and contributing in the field
of valuation to the government bodies, official liquidators of High Courts,
corporate entities, Individual citizens, commercial, co-operative and social organisations, firms and entities for last sixty years within the legally prescribed
framework. The regulation under supervision of Ministry of Finance shall not be
disregarded by Ministry of Corporate affairs, both ministries are part of one
government, one country. The purposes of regulation is same and it is for the
benefit of same service user. There are enough and good reasons for creating a
new regulation by allowing existing government registered valuers under section
34 AB of wealth tax act to be considered as government registered valuers under
section 247 of companies act 2013 without any examination. Exams may be
taken for new entrants or non registered valuers.

I am proposing an additional clause under Regulation framed for registration of
valuers under section 247 of the Companies Act 2013 Known as “ THE
COMPANIES (REGISTERED VALUERS AND VALUATION0 RULES,
2017” as under :

“All the existing and practicing Registered valuers under 34 AB of Wealth Tax Act
1957 shall be deemed eligible for Registration as Valuers under section 247 of
Companies Act 2013 in their respective categories subject to membership of
Registered Valuers Organization recognized under the Companies (Registered
Valuers and valuation) Rules 2017 published on 18.10.2017 and subject to
certificate of completion of prescribed training of 50 Hours by R.V. O, without
appearing for examination which is mandatory for all registered valuers.”
I have faith in your leadership and am having high hopes of your kind and sympathetic consideration of our request to benefit the profession.



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