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13. By placing reliance on the aforesaid decisions, the learned Senior counsel for the appellant would contend that while invoking the powers under Section 47-A (6) of the Act, the first respondent has to arrive at a subjective satisfaction that prejudice has been caused to the interest of revenue by reason of the order passed by his subordinates. However, the order, which is impugned in this appeal, was passed by the first respondent without any material evidence to show that there is prejudice caused to the interest of the revenue. The suo motu powers conferred with the first respondent under Section 47-A (6) of The Indian Stamp Act can be exercised only if the order passed by his subordinates, in exercise of power under Section 47-A (2) or 47-A (3) of the Indian Stamp Act, is prejudicial to the interest of the revenue, supported by material documents. In the present case, the first respondent has passed the order mechanically and enhanced the market value of the property without any reasons and in the absence of any evidence to show that prejudice has been caused to the interest of revenue by reason of an order passed by his subordinate. Therefore, the learned Senior counsel for appellant prayed to set aside the impugned order and allow this appeal.

19. The principal object with which The Indian Stamp Act, 1899 was enacted is to ensure generation of revenue and to protect the interest of revenue by adopting fiscal measures. For achieving the objects of this Act, certain yardsticks have to be adopted to ensure that the interest of the revenue is not in any manner prejudiced by reason of under quoting the value of a property or improper valuation of the property. Section 47-A (2) and 47-A (3) of the Act empower the authorities under the Act to cause appropriate enquiry, if, they have reason to believe that interest of revenue is in any way prejudiced by reason of under valuing the property or improperly valuing the property while registering an instrument before the competent registration authority. On the contrary, Section 47-A (6) of the Act empowers the Inspector General of Registration to cause suo motu enquiry if he was of the opinion, after arriving at a subjective satisfaction, that interest of revenue is prejudiced by reason of any order passed by his subordinates in exercise of the powers conferred on them under Section 47-A (2) and 47-A (3) of the Act. In other words, for invoking the powers conferred under Section 47-A (6) of the The Indian Stamp Act, the Chief Controlling Authority/ Inspector General of Registration has to record his subjective satisfaction that by reason of an order passed by his subordinates, interest of revenue is prejudiced or affected. Thus, by and large, the Act confers power upon the authorities under the Act largely to ensure that interest of revenue is fully and adequately protected. It is needless to mention that the suo-motu powers conferred on the Inspector General of Registration/Chief Controlling Revenue Authority can be exercised only on examination of the records of any proceedings under this Act and after arriving at a subjective satisfaction that the order passed by his subordinate is erroneous and he considers such an order passed is prejudicial to the interest of the revenue. Thus, only upon arriving at a subjective satisfaction as regards the prejudice caused to the interest of the revenue, the Inspector General of Registration can invoke the powers conferred under Section 47-A (6) of The Indian Stamp Act.

20. In the present case, a sale deed was presented for registration by the appellant on 11.09.2002 in which the appellant has valued the property at Rs.526/- per square feet and the total value of the property was arrived at Rs.4,68,00,000/-. According to the appellant, the guideline value of the property, at the time of presentation of the sale deed dated 11.09.2002 itself was Rs.325/- per square feet, however, the market value of the property was fixed at Rs.526/- per square feet. Inspite of the same, upon registration of the instrument, the third respondent doubted the value indicated thereon and therefore, he referred the instrument to the second respondent, as contemplated under Section 47-A of The Indian Stamp Act for determination of the correct market value. The second respondent, after conducting an enquiry, enhanced the market value from Rs.536/- per square feet to Rs.625/- per square feet, whereby the appellant was called upon to pay additional deficit stamp duty. The appellant also paid the sum of Rs.10,01,000/- being the differential stamp duty payable on the instrument on 08.11.2002. Notwithstanding the above, the first respondent, in exercise of his suo motu powers conferred under Section 47-A (6) of The Indian Stamp Act, 1989 has proposed to enhance market value and accordingly, by the order dated 06.10.2008, enhanced the market value from Rs.625/- per square feet to Rs.1,250/- per square feet. However, no reason was assigned as to how the interest of revenue is prejudiced by reason of the order passed by the second respondent enhancing the market value of the property to Rs.625/- per square feet.

23. In the present case, we also see that no reason was assigned by the first respondent to conclude that the market value of the property has to be fixed at Rs.1,250/- per square feet. Such conclusion arrived at by the first respondent is not supported by any material evidence or any arithmetical calculation. In the words of the Honourable Supreme Court in the case in (Steel Authority of India Limited vs., Sales Tax Officer, Rourkela-I Circle and others) reported in (2008) 16 VST 181 (SC) reasons are the heart-beat for any conclusion and in the absence of the same, the order passed by the authority cannot be sustained. Applying the said principle to the case on hand, we find that the order dated 06.10.2008 of the first respondent was passed by the first respondent without assigning any reasons. Therefore, we are of the view that the order dated 06.10.2008 of the first respondent is per se bereft of any material particulars and it was passed mechanically without any application of mind. We are also of the opinion that in the present case, the first respondent has not arrived at a subjective satisfaction, supported by any material evidence, to conclude that by reason of the order passed by his subordinates under Section 47-A (2) or 47-A (3) of The Indian Stamp Act, prejudice is caused to the interest of revenue warranting the first respondent to exercise his suo motu powers as contemplated under Section 47-A (6) of The Indian Stamp Act, 1989. Further, the appellant has given a detailed reply to the show cause notice repudiating the proposed enhancement with documentary evidence but the same has also not been considered by the first respondent. In any event, in the absence of any proof to show that interest of the revenue is prejudiced by reason of the orders passed by his subordinates, the impugned order passed by the first respondent, in exercise of suo motu powers conferred under Section 47-A (6) of The Indian Stamp Act, cannot sustain. Accordingly, we answer both the questions formulated in this appeal against the respondents and in favour of the appellant.