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3. Before going into the facts of this case the relevant provisions of the Indian Stamp Act can be usefully referred tO.S. 2 (10) of the Indian Stamp Act defines "conveyance" which is as follows;

2. (10) Conveyance includes a conveyance on sale and every instrument by which property, whether movable or immovable, is transferred inter vivos and which is not otherwise specifically provided for by Schedule I (or by Schedule I-A as the case may be.).

Article 23 of the Indian Stamp Act deals with conveyance as defined in Section 2(10) not being a transfer charged or exempted under Article 62. As per Article 23 stamp duty is payable as per the rate specified in the article on the value of consideration mentioned in the deed of conveyance. This Article was substituted by the Tamil Nadu Act XXV of 1967 by which the stamp duty is payable on the market value of the property covered as per the rates mentioned in the Article. There is no separate article for re-conveyance of property under an agreement of re-conveyance. But we find Article 54 of the Stamp Act deals with re-conveyance of mortgaged property for a market value equal to the amount of such consideration as set forth in the reconveyance.