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18. The object of the 1899 Act is to collect proper stamp duty on an instrument or conveyance on which such duty is payable. This is to protect the State revenue. The stamp duty is a revenue earned by the State. The intention to evade the stamp duty under valuing the price of the property is required to be prevented in order to protect the revenue of the State and if the price shown in the instrument is not a market price to the belief of the registering authority, the ascertainment and the determination may be made under Rule 3 of the West Bengal Stamp Duty (Prevention of under valuation of Instruments) Rules, 2001 (hereinafter referred to as the 2001 Rules). It is no longer res integra that when a property is sold by a competent Court through any Receiver by auction after publication in newspapers, the rigors of Section 47A of the 1899 Act would not be applicable [See the judgment delivered in the cases of V.N. Devadoss (supra) and Sati Enclave (supra)]. The contention of the State as regards under valuation of the property sold had been discounted by the Courts in the said judgments as in the facts of the said cases there was no basis for entertaining any belief that that the market value of the property had not been truly set forth with a view to fraudulently evade payment of proper stamp duty. The argument advanced on behalf of the State that the value set forth for sale cannot be termed as market value was also not accepted on the reasoning that market value is a changing concept and that the value fetched when sold in the open market after publication of advertisement and invitation of bids would be the market value and such open market sales are exempted from scrutiny under Section 47A of the 1899 Act.