Rule 150 explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
Rule 150 of the Income-tax Rules, 2026 determines fair market value on a section 247(9) reference three ways — stamp duty value for immovable property, the rule 57 method for jewellery and securities, and open market price for everything else.
The three bases
| Clause | Property | Basis |
|---|---|---|
| (a) | Immovable property, being land or building or both | The value adopted or assessed or assessable by any authority of the Central Government or a State Government for the purpose of payment of stamp duty, along with the cost of construction and improvements, if any |
| (b) | Jewellery, archaeological collections, drawings, paintings, sculptures, any work of art, shares or securities referred to in rule 57 | The value determined in the manner provided in rule 57 |
| (c) | Property other than those in (a) and (b), or where the valuation specified in those clauses is not feasible | The price that such property would ordinarily fetch on sale in the open market |
In all three, the valuation is made on the date or dates on which such property is required to be valued as per the reference made under section 247(9). The 1962 parallel is rule 13A.
Clause (a) of rule 150 does not stop at the circle rate. It adds the cost of construction and improvements, if any — so a plot valued for stamp duty as land, on which a building has since been put up, is valued at the stamp duty figure plus that construction cost. Reporting only the stamp duty value understates a developed property, sometimes very substantially.
The date rule
Sub-rule (1)(b) contains a specific override: the reference to the valuation date in rules 56 and 57 shall be the date or dates on which such property is required to be valued as per the reference made under section 247(9).
Rules 56 and 57 ordinarily carry their own valuation dates — the date property or consideration is received for section 92, the date an unquoted share is transferred for section 79, the date inventory is converted for section 26(2)(j). Rule 150 displaces all of them and substitutes the date named in the reference. A valuer applying rule 57 on a section 247(9) reference must therefore take the date from the reference, not from rule 56.
The phrase repeats in all three clauses: "the date or dates on which such property is required to be valued". A reference may ask for a valuation at more than one point in time — typically to establish a value at acquisition and at another moment. The report has to answer each date the reference specifies.
The feasibility fallback
Clause (c) is drafted with two limbs. It applies to property outside clauses (a) and (b), and to property within them "where valuation as specified in the said clauses is not feasible".
So the open market test is both a residual category and a fallback. Where an immovable property has no stamp duty value adopted, assessed or assessable — or where a rule 57 valuation cannot be carried out on the material available — the valuer moves to what the property would ordinarily fetch on sale in the open market, and should record why the primary basis was not feasible.
Who reports, and in what form
Sub-rule (2): the Valuation Officer, the person registered under section 514, or any person or entity approved under section 247(9), to whom the reference has been made by the authorised officer, shall submit the report of valuation in Form No. 170 to that authorised officer.
The eligible reporters are exactly those rule 149 allows to be approved for a section 247(9) reference — so the two rules work together: rule 149 decides who may be referred to, and rule 150 decides how they must value and in what form they must report.
Worked example
| Property | Valuation under rule 150 |
|---|---|
| Residential flat | Stamp duty value at the reference date, plus the cost of any improvements |
| Vacant plot with a factory built on it after purchase | Stamp duty value plus the construction cost |
| Gold jewellery | Valued under rule 57, with the reference date substituted |
| Unquoted equity shares | Rule 57 method, again on the reference date |
| A painting | Rule 57 — works of art are within clause (b) |
| Bearer instruments with no rule 57 route available | Open market price under clause (c) |
| Land in an area with no notified stamp duty value | Open market price — clause (a) not feasible |
| Reference asks for values at two dates | Report both, in Form No. 170 |
Compliance checklist
- Read the date or dates from the section 247(9) reference before anything else.
- For immovable property, take the stamp duty value and add construction and improvement cost.
- For jewellery, art, shares and securities, apply rule 57, substituting the reference date for the rule 56 valuation date.
- Use the open market price for other property, and where the primary basis is not feasible.
- Record the reason where a primary basis was found not feasible.
- Confirm the valuer is a Valuation Officer, a section 514 registered person, or approved under section 247(9).
- Submit the report in Form No. 170 to the authorised officer.
- Answer every date the reference specifies.
Common mistakes
- Reporting the stamp duty value alone for a developed property.
- Using the rule 56 valuation date instead of the reference date.
- Going straight to open market value where a stamp duty or rule 57 basis exists.
- Answering only one of several dates in the reference.
- Reporting other than in Form No. 170.