A Land-Holding Company's Shares Are an SFA Job. The Land Underneath Isn't.
A company with no business at all, just land and building on its balance sheet, still needs its equity shares valued the same as any other company. The engagement is squarely Securities or Financial Assets. The land inside the number is not, and the Rules block the SFA valuer from certifying it alone.
The Engagement Is SFA, Full Stop
Shares are securities, and valuing them is a Securities or Financial Assets engagement under Annexure IV of the Companies (Registered Valuers and Valuation) Rules, 2017, regardless of what sits behind the shares on the balance sheet. Only a valuer registered for that asset class may be engaged for the job. Annexure IV's own SFA qualification criteria run entirely through finance and accounting credentials, ICAI, ICSI, or ICMAI membership, an MBA in finance, or a postgraduate diploma in business management, with no real estate, civil engineering, or land-appraisal competence required anywhere in the list.
Rule 7(c) Blocks That Valuer From Doing the Land Themselves
Rule 7(c) is direct: a registered valuer shall "not conduct valuation of the assets or class(es) of assets other than for which he/it has been registered." An SFA valuer holds no Land and Building registration, so certifying the land figure under their own licence is exactly what this Rule exists to prevent. The Rules do not leave this to inference; the IBBI's own registration FAQ states the same limit in plain terms: "a registered valuer can undertake valuation of assets only for the class of asset for which he/she is registered for."
Rule 8(2) Is the Built-In Route Around It
The same Rules supply the mechanism for exactly this situation. Rule 8(2) lets a registered valuer "obtain inputs for his valuation report or get a separate valuation for an asset class conducted from another registered valuer," provided the inputs and the other valuer's particulars are fully disclosed, and the resulting liability "irrespective of the nature of inputs or valuation by the other registered valuer, shall remain of the first mentioned registered valuer." The SFA valuer obtains the land figure from a Land and Building valuer, discloses it, and signs the share valuation alone, carrying full liability for the number regardless of whose appraisal fed into it.
ICAI and IVS Recognise the Case, But Don't Mandate the Second Signature
ICAI Valuation Standard 301 names this exact fact pattern directly, instructing a valuer to consider "whether the underlying business is an operating company, a real estate or investment holding company, or a company with substantial non-operating or excess assets," and requires such assets valued at realisable value and added to the figure from the primary approach. International Valuation Standards runs the identical instruction in IVS 200. Neither standard, nor ICAI VS 201's own "reliance on the work of other experts" provision, requires that the other expert hold any particular licence. IVS's "Use of a Specialist" standard is explicitly permissive, "it is acceptable" to bring one in "if the valuer does not possess the necessary technical skills," not a mandate that they must. The requirement that the other expert be specifically a registered valuer comes from Rule 8(2) itself, not from the valuation standards governing how the work gets done.
What This Means in Practice
One engagement is legally required, and it is SFA. But given Annexure IV's SFA criteria carry no land-appraisal competence at all, an SFA valuer relying purely on their own judgement for the land figure is a hard position to defend if questioned, and Rule 7(c) forecloses it as a matter of registration anyway. Rule 8(2)'s disclosed-input mechanism is the compliant path: an L&B valuer's figure goes in, one SFA signature goes out, and one valuer carries the liability for the whole number. Practically, both licences end up in the room. Only one of them signs.