Market Value, Book Value, Stamp-Duty Value and ED Valuation Disputes under PMLA

PMLA • ED • VALUATION • FAIR MARKET VALUE • BOOK VALUE • CIRCLE RATE • LAND • MACHINERY • JEWELLERY • SHARES • CRYPTO

A 2026 depth guide to Section 2(1)(zb) PMLA, valuation dates, methodology disputes, asset-class documentation, market-linked assets and challenging unsupported or excessive ED valuations.

By Advocate Ankit Kumar Singh

Updated: 8 August 2026

The First Mistake in a PMLA Valuation Case: Treating Every “Value” as the Same Number

A property under investigation can simultaneously have:

• a purchase price;
• a figure in the sale deed;
• a stamp-duty value;
• a circle or guideline rate;
• a current market price;
• a book value;
• a written-down accounting value;
• a liquidation value;
• and a statutory value under PMLA.

These figures answer different questions.

They should not be mechanically substituted for one another.

The proper starting point is:

WHAT VALUATION DOES THE PMLA ACTUALLY REQUIRE FOR THIS PROPERTY AND THIS ATTACHMENT THEORY?

Section 2(1)(zb) — The Statutory Definition of “Value”

PMLA contains an express definition.

In substance, “value” means the fair market value of any property on the date of its acquisition, or where that date cannot be determined, the date on which the property is possessed.

That has two major consequences:

1. The statute speaks of fair market value, not automatically book value.
2. The relevant statutory date is not automatically the PAO date or today's market date.

There Is No Statutory Category Called “ED Value”

An attachment order may describe an asset using:

CIRCLE RATE / BOOK VALUE / MARKET VALUE / VALUER'S FIGURE.

But the fact that a figure appears in a PAO does not create a fourth type of value called:

“ED VALUE.”

The defence can ask:

• Who calculated it?
• On what date?
• Using what methodology?
• Using what comparable transactions?
• Was the asset physically inspected?
• Were encumbrances considered?
• Was the correct ownership share valued?
• Does the figure comply with Section 2(1)(zb)?

Market Value vs Fair Market Value

The terms are often used casually, but a defensible fair-market valuation should identify:

• the asset being valued;
• the valuation date;
• its legal and physical attributes;
• available market evidence;
• assumptions;
• encumbrances;
• methodology;
• valuation conclusion.

A current broker's verbal estimate is not automatically the statutory fair market value of property acquired ten years earlier.

Book Value — Useful Accounting Evidence, Not an Automatic FMV

Book value may represent:

• historic purchase cost;
• cost less depreciation;
• carrying value;
• gross block;
• inventory cost;
• a revalued accounting figure.

A plot purchased for ₹50 lakh may remain at ₹50 lakh in historic accounts while the market has changed substantially.

Conversely, machinery purchased for ₹5 crore may have a substantially lower resale value after years of use.

Therefore:

BOOK VALUE IS EVIDENCE. IT IS NOT AUTOMATICALLY SECTION 2(1)(zb) FAIR MARKET VALUE.

Malwa Real Estate 2025 — Why the Acquisition Date Matters

In M/s Malwa Real Estate Developing Pvt. Ltd. v. Union of India, the challenged PAO attached land at approximately ₹4.63 crore, being the acquisition/book figure recorded by ED.

The petitioner argued that present market value was substantially different and challenged the statutory valuation provision.

The another Indian jurisdiction High Court reproduced Section 2(1)(zb) and held that the definition of value must be read together with “property” and “proceeds of crime”.

The constitutional challenge was rejected.

The key practical lesson is:

DO NOT ASSUME THE ATTACHMENT DATE'S MARKET PRICE IS THE STATUTORY VALUATION DATE.

Stamp-Duty Value / Circle Rate / Guideline Value

Government guideline or circle values are principally used for:

• stamp-duty administration;
• registration;
• minimum value references;
• certain tax consequences under other laws.

They can be useful evidence.

But they should not automatically be equated with actual transactional FMV.

A circle value may be:

• below actual market transactions;
• above the price realistically obtainable;
• insensitive to floor or orientation;
• insensitive to litigation;
• insensitive to tenancy;
• insensitive to access problems;
• based on broad locality categories.

Therefore the defence should ask:

WHY HAS A STAMP-DUTY BENCHMARK BEEN TREATED AS THE FINAL PMLA FMV?

LAND & PLOTS — Practical Valuation Objections

For land, the valuation should consider more than acreage.

Check:

• exact survey / khata / plot number;
• area actually owned;
• ownership share;
• agricultural / residential / commercial use;
• conversion status;
• road access;
• frontage;
• shape and dimensions;
• development restrictions;
• leasehold vs freehold;
• encumbrances;
• litigation;
• tenancy / possession;
• comparable transactions close to the valuation date.

Documents Required — Land

• registered sale deed;
• agreement and prior title deeds;
• mutation / revenue record;
• survey map;
• land-use certificate;
• conversion order where applicable;
• circle/guideline rate applicable on relevant date;
• comparable registered sale deeds;
• property-tax record;
• encumbrance certificate;
• mortgage / charge documents;
• litigation orders;
• independent land-and-building valuation report;
• photographs / site plan.

FLATS & BUILDINGS — Do Not Value Them Like Bare Land

A flat valuation may require:

• carpet area;
• built-up / super-built-up area;
• undivided land share;
• floor;
• building age;
• construction quality;
• parking rights;
• occupancy status;
• leasehold/freehold status;
• maintenance liabilities;
• structural condition;
• local comparable sales;
• development / completion approvals.

A generic:

AREA × CIRCLE RATE

may therefore fail to capture the actual asset being valued.

Documents Required — Flat / Building

• allotment letter;
• builder-buyer agreement;
• registered deed;
• possession certificate;
• completion / occupancy certificate where available;
• sanctioned plan;
• area statement;
• maintenance record;
• parking allotment;
• property tax;
• home-loan valuation;
• historic bank valuation report;
• comparable sale deeds;
• independent valuation report.

STOCK-IN-TRADE / INVENTORY — Book Stock Is Not Necessarily Market Value

Business inventory may include:

• raw material;
• work in progress;
• finished goods;
• obsolete goods;
• slow-moving stock;
• expired goods;
• damaged stock.

The ledger may state inventory of:

₹10 CRORE.

That does not automatically mean ₹10 crore could actually be realised.

Check:

• physical quantity;
• ageing;
• condition;
• obsolescence;
• marketability;
• expiry;
• NRV / realisable price;
• third-party ownership;
• goods held on consignment.

Documents Required — Inventory

• stock register;
• physical stock verification report;
• SKU / lot-wise list;
• purchase invoices;
• sales invoices;
• GST records;
• e-way bills;
• warehouse records;
• ageing analysis;
• expiry / damage records;
• audited financial statements;
• insurance records;
• independent inventory valuation.

PLANT & MACHINERY — Original Cost Is Usually the Wrong Question

A machine purchased for:

₹8 CRORE

ten years earlier may not be worth ₹8 crore today.

Equally, a fully depreciated machine in the books may still have substantial operational value.

Therefore distinguish:

ORIGINAL COST

from:

ACCOUNTING WDV

from:

FAIR MARKET VALUE.

Plant & Machinery — What the Valuer Should Examine

• manufacturer;
• model;
• serial number;
• year of manufacture;
• installation date;
• capacity;
• operating hours;
• maintenance history;
• physical condition;
• technological obsolescence;
• economic obsolescence;
• remaining useful life;
• availability of spare parts;
• dismantling cost;
• transport / reinstallation cost;
• forced-sale market;
• hypothecation / charge.

Documents Required — Plant & Machinery

• purchase invoices;
• import documents where relevant;
• asset register;
• depreciation schedule;
• installation report;
• serial-number schedule;
• maintenance logs;
• insurance valuation;
• bank valuation;
• hypothecation documents;
• production records;
• inspection photographs;
• independent Plant & Machinery valuer's report.

JEWELLERY — Weight × Gold Rate Is Often Too Crude

Jewellery requires separation of:

• gross weight;
• net precious-metal weight;
• purity;
• stones;
• diamonds;
• making charges;
• antique / collectible component;
• resale deductions.

A retail showroom replacement price may be materially different from:

FAIR REALISABLE VALUE.

Gold, Diamonds and Precious Stones

For gold:

• record purity;
• record net weight;
• identify rate and valuation date;
• separate bullion from ornaments.

For diamonds and stones:

• carat;
• cut;
• colour;
• clarity;
• certification;
• individual stone valuation.

Do not accept:

“TOTAL JEWELLERY WEIGHT × 24-CARAT GOLD RATE”

where the articles contain 22K/18K metal, stones or non-gold components.

Documents Required — Jewellery / Bullion

• seizure inventory;
• article-wise photographs;
• gross and net weight sheet;
• hallmark / purity details;
• purchase invoices;
• wealth / asset disclosures where relevant;
• insurance valuation;
• diamond certificates;
• independent jewellery valuation;
• market-rate source for the specified valuation date.

CASH — The Simplest Asset Can Still Produce Evidentiary Disputes

For Indian currency, the face value is ordinarily self-evident.

But the defence should still verify:

• denomination-wise count;
• seizure memo;
• total arithmetic;
• ownership;
• cash book;
• source;
• business receipts;
• recent bank withdrawals;
• whether the same cash has been attributed to more than one person.

For foreign currency, also identify:

• currency;
• quantity;
• exchange-rate source;
• date/time used for INR conversion.

Fixed Deposits — Principal, Accrued Interest or Maturity Value?

An FD can generate an avoidable valuation dispute.

Possible numbers include:

• original principal;
• current outstanding amount;
• principal plus accrued interest;
• premature-redemption value;
• maturity value.

The PAO should make clear which figure has been used.

Do not allow:

Maturity value five years later

to be silently treated as though it were the present attached corpus without explaining the valuation theory.

Documents Required — FDs

• FD receipt;
• bank confirmation;
• principal amount;
• deposit date;
• maturity date;
• interest rate;
• accrued interest statement;
• premature-redemption terms;
• source account;
• lien / pledge details;
• TDS / interest certificate.

LISTED SHARES — Value Changes Every Trading Day

Listed equity raises at least three different questions:

1. WHAT WAS THE VALUE ON THE RELEVANT DATE?

2. WHAT PRICE SOURCE WAS USED?

3. WHAT HAPPENS WHEN THE VALUE MOVES AFTER FREEZING?

A defensible report should state whether it used:

• closing price;
• VWAP;
• another exchange-derived price;
• and why.

PMLA does not prescribe a universal intraday pricing formula for listed shares.

Prakash Industries — Appreciation of Tainted Shares Can Matter

The Delhi High Court's November 2025 Directorate of Enforcement v. Prakash Industries Ltd. is important for another reason.

The Court held, on the facts and legal theory before it, that where tainted money is invested and the resulting shares appreciate, the enhanced value can remain indirectly derived from the original illicit source.

Therefore:

DO NOT READ SECTION 2(1)(zb) AS A UNIVERSAL RULE THAT EVERY ACTUAL POC ASSET IS FOREVER FROZEN AT ITS HISTORIC PURCHASE PRICE.

Actual tainted property and substitute/equivalent-value property must be analysed separately.

Dream Achiever 2026 — Frozen Shares Must Also Preserve Economic Value

In Dream Achiever Consultancy Services v. Union of India, the frozen DEMAT portfolio was valued at approximately ₹423.60 crore when frozen.

The another Indian jurisdiction High Court recognised that listed shares can appreciate or depreciate materially while proceedings remain pending.

The Court held that preserving attached property can include preserving its economic worth.

It permitted the petitioners to submit a proposal for liquidation and possible reinvestment under ED supervision, with the corpus remaining outside their control.

This creates an important modern valuation principle:

FOR VOLATILE ASSETS, PRESERVING THE ASSET AND PRESERVING ITS ECONOMIC VALUE MAY NOT ALWAYS BE THE SAME THING.

Documents Required — Listed Shares

• DEMAT statement;
• ISIN;
• quantity;
• acquisition dates;
• contract notes;
• purchase-price history;
• corporate-action history;
• bonus / split records;
• dividend records;
• NSE/BSE price evidence on valuation date;
• pledge / lien details;
• valuation working;
• current-value preservation proposal where required.

UNLISTED SHARES — Book Value Is Particularly Dangerous

For an unlisted company, there may be no daily market quote.

Possible professional approaches may include:

• net asset approach;
• earnings / income approach;
• discounted cash flow;
• comparable transactions;
• market multiples;
• hybrid methodologies.

Which method is appropriate depends on the company and valuation purpose.

The defence should be suspicious of:

“FACE VALUE ₹10 = SHARE VALUE ₹10”

and equally:

“NET ASSET VALUE = AUTOMATIC FAIR MARKET VALUE.”

Unlisted Share Valuation — What Must Be Checked?

• exact share class;
• equity / preference rights;
• number of shares;
• fully diluted capital;
• latest audited accounts;
• debt;
• contingent liabilities;
• subsidiary value;
• related-party transactions;
• minority discount where relevant;
• control premium where relevant;
• transfer restrictions;
• recent arm's-length transactions;
• valuer methodology.

Documents Required — Unlisted Shares

• share certificate / DEMAT proof;
• cap table;
• register of members;
• PAS-3 / allotment records;
• articles of association;
• shareholder agreements;
• audited financial statements;
• latest management accounts;
• business projections where DCF is used;
• recent funding transactions;
• debt schedule;
• existing valuation reports;
• independent Securities or Financial Assets valuation.

MUTUAL FUNDS & OTHER MARKET-LINKED SECURITIES

For mutual funds, identify:

• scheme;
• units;
• NAV date;
• encumbrance;
• exit load;
• redemption restrictions;
• corporate actions.

For bonds/debentures:

• face value;
• coupon;
• maturity;
• credit quality;
• listed/unlisted status;
• market yield;
• accrued interest;
• default status.

CRYPTOCURRENCY / VIRTUAL DIGITAL ASSETS — The Timestamp Is Part of the Valuation

A cryptocurrency figure can move materially within minutes.

A defensible valuation therefore requires more than:

“BITCOIN PRICE = ₹___.”

Identify:

• token;
• network;
• quantity;
• wallet;
• exchange;
• valuation date;
• exact time and timezone where material;
• quoted currency;
• INR conversion rate;
• liquidity;
• restrictions / staking / lock-up;
• price source.

No Uniform PMLA Crypto Pricing Formula

PMLA does not presently prescribe a universal rule saying:

USE EXCHANGE X AT MIDNIGHT AT CLOSING PRICE.

For a highly liquid VDA, a professional valuation may consider reliable spot-market data from established trading venues.

For a thinly traded token, a single last-traded price can be misleading.

Potential issues include:

• very low trading volume;
• artificial last trades;
• wide bid-ask spreads;
• exchange-specific premiums;
• token lock-up;
• vesting;
• stablecoin de-pegging;
• lack of INR liquidity.

Documents Required — Crypto / VDA

• wallet addresses;
• transaction hashes;
• token and network;
• exchange account statements;
• deposit / withdrawal history;
• quantity on exact valuation date;
• proof of wallet control;
• price-source screenshots/data;
• timestamp and timezone;
• INR FX methodology;
• liquidity / trading-volume data for illiquid assets;
• staking / lock-up agreements;
• independent VDA / financial-asset valuation where necessary.

The Valuation-Date Trap

A large number of disputes can be reduced to:

RIGHT ASSET, WRONG DATE.

For example:

Property acquired: 2012.

PAO: 2026.

ED relies upon: 2026 real-estate price.

If the legal issue requires application of Section 2(1)(zb), the defence should immediately ask:

WHY IS THE 2026 PRICE THE RELEVANT STATUTORY VALUE?

The Quantity Trap

Sometimes the rate is correct, but the quantity is wrong.

Examples:

• 100% property valued though accused owns only 50%;
• gross jewellery weight used instead of gold weight;
• obsolete inventory counted as saleable stock;
• bonus shares omitted;
• pledged securities counted twice;
• crypto quantity includes coins moved out before valuation date.

Always audit:

QUANTITY × RATE

before arguing about the rate itself.

The Ownership Trap

A ₹10 crore property is not necessarily a ₹10 crore asset of one accused.

Check:

• joint ownership;
• undivided shares;
• partnership interests;
• company ownership;
• beneficial ownership allegations;
• mortgage;
• third-party rights.

Valuation should follow the interest actually being proceeded against.

The Encumbrance Question

Consider:

Market value: ₹20 crore.

Outstanding secured loan: ₹14 crore.

Should the attached interest simply be described as ₹20 crore without discussing the lender's pre-existing security?

The defence should place the encumbrance and priority rights on record.

Do not assume that gross asset value and owner's unencumbered economic interest are the same concept.

Over-Valuation Can Produce Over-Attachment

Suppose alleged POC:

₹10 CRORE.

ED attaches:

• land stated at ₹6 crore;
• machinery stated at ₹5 crore;
• shares stated at ₹4 crore.

Total headline value:

₹15 CRORE.

A valuation objection should examine:

WHETHER THE AGGREGATE ATTACHMENT EXCEEDS THE PROPERLY ATTRIBUTABLE AND UNSATISFIED POC VALUE.

Prepare a Master Asset-Valuation Reconciliation

Asset	ED Value	ED Basis	Correct Date?	Defence Value	Evidence
Land	₹___	Circle / Market	Yes / No	₹___	Valuer + comparables
Machinery	₹___	Book Cost	Yes / No	₹___	P&M Valuation
Shares	₹___	Market / NAV	Yes / No	₹___	Exchange / SFA Valuer
Crypto	₹___	Exchange Price	Yes / No	₹___	Wallet + price data

How to Structure a Valuation Objection before the Adjudicating Authority

GROUND I — Wrong Legal Valuation Date

Identify Section 2(1)(zb) and the date actually used by ED.

GROUND II — Wrong Valuation Concept

Explain why:

BOOK VALUE / CIRCLE VALUE / RETAIL VALUE

is not automatically the required FMV.

GROUND III — Wrong Asset Quantity

Challenge area, weight, units, shares, tokens or ownership percentage.

GROUND IV — Wrong Methodology

Identify methodological defects and supply a counter-valuation.

GROUND V — Ignored Encumbrances

Place mortgages, pledges, charges and third-party interests on record.

GROUND VI — Asset Condition Ignored

Especially for:

• machinery;
• inventory;
• unfinished buildings;
• jewellery;
• illiquid securities.

GROUND VII — Valuation vs Nexus

State separately that:

EVEN A CORRECTLY VALUED PROPERTY DOES NOT BECOME POC WITHOUT THE REQUIRED STATUTORY BASIS.

GROUND VIII — Cumulative Over-Attachment

Compare all assets already frozen, seized or attached.

What Should a Counter-Valuation Report Contain?

• identity and qualification of valuer;
• asset class;
• purpose of valuation;
• valuation date;
• ownership documents;
• physical inspection where applicable;
• quantity;
• methodology;
• comparables;
• assumptions;
• encumbrances;
• limitations;
• supporting data;
• final calculation;
• photographs / schedules where appropriate.

A one-page certificate stating only:

“IN MY OPINION THE PROPERTY IS WORTH ₹___”

is substantially weaker than a transparent valuation report whose calculation can be independently tested.

Frequently Asked Questions

What does “value” mean under PMLA?

Section 2(1)(zb) defines it as fair market value on the date of acquisition, or if that date cannot be determined, the date of possession.

Is current market value always used?

No. The statutory valuation date must first be identified.

Is book value equal to PMLA value?

Not automatically. Book value is an accounting concept and may differ materially from fair market value.

Is circle rate the same as market value?

Not necessarily. It is an official valuation benchmark used primarily in stamp/registration administration and may be useful evidence, but the actual PMLA valuation question must still be analysed.

Can ED use circle value?

It can form part of the valuation material, but the defence can question why it properly represents the statutory FMV for the relevant asset and date.

Can ED value land at today's price when it was bought ten years ago?

That depends upon the precise legal theory. Where Section 2(1)(zb)'s statutory value is being applied, the acquisition-date requirement becomes critical.

Can an old property's book value be used?

It may be evidentiary, but whether it represents acquisition-date FMV requires examination.

How should machinery be valued?

A proper valuation should consider age, condition, capacity, obsolescence, remaining useful life and market evidence, not merely original invoice cost or accounting WDV.

Can fully depreciated machinery still have value?

Yes. Accounting depreciation does not necessarily mean zero market value.

Can old inventory be valued at full ledger cost?

Not automatically. Ageing, damage, obsolescence, expiry and realisable value should be considered.

How is gold jewellery valued?

The analysis should separate net precious-metal weight, purity, stones, diamonds and other components using an identified valuation date.

Can retail jewellery price be used?

The defence should question whether a showroom replacement price, including making charges, properly represents the relevant fair-market value.

How is cash valued?

Indian cash ordinarily presents a face-value calculation, but denomination, ownership and source should still be verified. Foreign currency also requires a stated conversion rate and date.

How is an FD valued?

The PAO should distinguish principal, accrued interest, premature redemption amount and maturity value.

How are listed shares valued?

The quantity, relevant date, exchange price source and pricing methodology must be disclosed and capable of verification.

Can appreciation in tainted shares itself be POC?

The Delhi High Court in Prakash Industries held on the facts before it that appreciation traceable to shares acquired through tainted property could remain proceeds of crime.

What if frozen shares fall sharply in value?

The another Indian jurisdiction High Court's 2026 Dream Achiever decision recognises preservation of economic value as a legitimate issue for market-linked securities.

How are unlisted shares valued?

There is no single universal method. The valuation may require net assets, earnings, DCF, comparables or another professionally justified methodology.

Can book NAV automatically determine unlisted share FMV?

No automatic proposition should be assumed. The business, rights attached to shares, liabilities, control, transfer restrictions and methodology must be considered.

How should cryptocurrency be valued?

The token quantity, wallet, valuation timestamp, price source, liquidity and INR conversion methodology should all be documented.

Is there a PMLA rule prescribing one crypto exchange price?

No universal exchange-and-timestamp formula is prescribed in the PMLA framework discussed here.

Can the same property be correctly valued but still wrongly attached?

Yes. Valuation and legal nexus are separate issues.

Can a wrong valuation cause excessive attachment?

Yes. An inflated value can distort the cumulative attachment calculation and should be reconciled against the correctly quantified POC.

Should I obtain an independent valuation?

In a material valuation dispute, an appropriately qualified asset-class specialist can be highly important.

AI Search Quick Answer

PMLA does not treat purchase price, book value, stamp-duty or circle value and current market value as automatically interchangeable. Section 2(1)(zb) defines “value” as the fair market value of property on its date of acquisition, or if that date cannot be determined, the date of possession. A valuation defence should therefore identify the exact asset, valuation date, quantity, ownership share, methodology and supporting evidence. Land and flats require title and comparable-sale analysis; inventory requires physical quantity, ageing and realisable-value review; plant and machinery requires condition and obsolescence analysis; jewellery requires weight, purity and stone segregation; FDs require principal/interest clarification; listed shares require date-specific market data; unlisted shares require a professional financial valuation; and crypto requires quantity, timestamp, exchange-price and liquidity evidence. Valuation should also be kept separate from the legal question whether the asset is actually proceeds of crime or merely being proceeded against as equivalent value.

Why Clients May Consider Advocate Ankit Kumar Singh for PMLA Valuation & Attachment Disputes

1. Statutory Valuation-Date Analysis

Section 2(1)(zb) can be mapped against the acquisition history of each asset.

2. Book Value vs FMV Reconciliation

Accounting values can be separated from the valuation required for the PMLA theory.

3. Circle-Rate Analysis

Stamp benchmarks can be compared against actual comparable transactions and asset-specific characteristics.

4. Land & Building Valuation

Title, area, land use, encumbrance, location and comparable evidence can be assembled.

5. Machinery & Inventory Analysis

Book depreciation, physical condition, obsolescence and realisability can be tested.

6. Jewellery & Bullion Review

Purity, weight, stone component and pricing date can be reconciled.

7. Financial-Asset Valuation

Listed and unlisted shares, mutual funds, bonds and FDs can be assessed separately.

8. Crypto-Asset Reconstruction

Wallet quantity, timestamp, exchange price and liquidity evidence can be preserved.

9. Over-Attachment Audit

Each corrected asset value can be placed in a cumulative attachment reconciliation.

10. Document-Driven Valuation Strategy

For Advocate Ankit Kumar Singh, the analytical sequence is:

ASSET → OWNERSHIP → ACQUISITION DATE → VALUATION DATE → QUANTITY → ED METHODOLOGY → COUNTER-VALUATION → POC / EQUIVALENT-VALUE THEORY → CUMULATIVE ATTACHMENT → SECTION 8 → APPEAL.

No de-attachment, valuation reduction, appeal or High Court outcome is guaranteed.

Primary Research Basis

• Prevention of Money-Laundering Act, 2002 — Sections 2(1)(u), 2(1)(v), 2(1)(zb), 5 and 8.
• Prevention of Money-laundering (Taking Possession of Attached or Frozen Properties Confirmed by the Adjudicating Authority) Rules, 2013.
• M/s Malwa Real Estate Developing Pvt. Ltd. v. Union of India — another Indian jurisdiction High Court, 20 February 2025.
• Directorate of Enforcement v. M/s Prakash Industries Ltd. — Delhi High Court, 3 November 2025.
• M/s Dream Achiever Consultancy Services Pvt. Ltd. & Others v. Union of India — another Indian jurisdiction High Court, 27 April 2026.
• Companies (Registered Valuers and Valuation) Rules, 2017 — used only as a professional asset-class valuation reference and not presented as the statutory PMLA valuation code.

Conclusion

A PMLA valuation dispute should never begin with:

“THE PROPERTY IS NOT WORTH THAT MUCH.”

Begin with:

WHAT PROPERTY?

WHO OWNS IT?

WHAT QUANTITY OR SHARE?

WHAT IS THE ACQUISITION DATE?

WHAT IS THE STATUTORY VALUATION DATE?

WHAT METHOD DID ED USE?

WHAT DOCUMENTS SUPPORT THAT METHOD?

IS THIS ACTUAL POC OR EQUIVALENT-VALUE PROPERTY?

HOW MUCH POC IS ALREADY SECURED?

Then calculate.

VALUE IS NOT A LABEL. IT IS A DATE-SPECIFIC, ASSET-SPECIFIC, METHODOLOGY-SPECIFIC EVIDENTIARY CONCLUSION.

That principle applies differently to land, flats, inventory, machinery, gold, cash, fixed deposits, shares and cryptocurrency.

The stronger defence therefore uses:

LEGAL VALUATION DATE + SPECIALIST VALUER + SOURCE DOCUMENTS + TRANSPARENT CALCULATION + CUMULATIVE ATTACHMENT AUDIT.

Legal & Research Disclaimer: This article is intended for general legal education and professional information. The terms market value, fair market value, book value, written-down value, stamp-duty value, circle value, liquidation value and current economic value are not treated as interchangeable. Section 2(1)(zb) PMLA contains the statutory definition of “value”. The appropriate valuation methodology depends upon the asset, the valuation date, the attachment theory and the available evidence. This article does not state that the Companies (Registered Valuers and Valuation) Rules, 2017 constitute the statutory valuation mechanism under PMLA; that framework is referred to only as a useful professional asset-class reference. No universal PMLA methodology is asserted here for cryptocurrency, unlisted shares, jewellery or other specialised assets where the statute does not prescribe a detailed pricing formula. A valuation report does not itself decide whether property constitutes proceeds of crime. Likewise, a source-of-funds defence, ownership dispute, equivalent-value issue and valuation dispute may require separate legal findings. No guarantee is made regarding valuation reduction, release of property, Section 8 adjudication, Appellate Tribunal proceedings, Special Court proceedings or High Court relief.

Related Delhi legal guides

PMLA provisional attachment · Adjudicating Authority procedure · PMLA Appellate Tribunal

Official starting points

Prevention of Money-laundering Act, 2002 — India Code · Directorate of Enforcement — official website

Document-first assessment

Start with the latest legal instrument and next deadline

Organise the current summons or order, case identifiers, a dated chronology and the transaction or property record before seeking case-specific advice.

Prepare for consultation