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13. The instruments, the subject matter of present appeals are deeds of conveyance as defined under Section 2(10) and there is no controversy in this respect. In terms of Schedule I entry 23, Stamp Duty is payable on the market value of the property, which is the subject matter of conveyance.

14. Section 47-A of the Stamp Act provides for the registering officer, while registering any instrument of conveyance, exchange, gift or lease of benami rights or settlement has reason to feel that the market value of the property, which is the subject matter of conveyance has not been truly set forth in the instrument, he may, after registering the said instrument, refer the same to the Collector for determination of the market value of such property and the appropriate duty payable thereon.

15. In terms of Section 47-A, it is for the registering authority appointed under the Registration Act, who should have reason to believe that the market value of the property has not been truly set forth in the instrument. This is not the case here. What is the view of the registering authority being the lands are proposed to be used for industrial purposes and, therefore, it has to be valued as such, which is not a relevant consideration at all. The market value of the land has to be valued as on the date of the deed of conveyance and it may not depend upon future or intended user of the land by the purchaser.

19. In Collector of Nilgiris v. Mahavir Plantations Pvt. Ltd., , while considering the scope of Section 47-A of The Stamp Act, this Court held thus :

"The valuation guidelines prepared by the Revenue Officials at the instance of the Board of Revenue were avowedly intended merely to assist the Sub-Registrars to find out, prima facie, whether the market value set out in the instruments had been set forth correctly. The guidelines were not intended as a substitute for market value or to foreclose the inquiry by the Collector which he is under a duty to make under Section 47-A. The valuation guidelines were not prepared on the basis of any open hearing of the parties concerned or of any documents. They were based on data gathered broadly with reference to classification of lands, grouping of lands and the like. This being so, the Collector acting under Section 47-A cannot regard the valuation guidelines as the last word on the subject of market value. To do so would be to surrender his statutory obligation to determine market value on the basis of evidence, which is a judicial or a quasi judicial function which he has to perform."

24. Sub-rule (3) confers power on the registering officer, for the purpose of finding out whether the market value has been correctly furnished in the instrument, make such enquiries as he may deem fit and he may also elicit from the authorities concerned any information bearing on the subject and call for and examine any record kept with any public officer or authority. The sub-rule provides that the registering officer may also look into the guidelines register containing the value of property supplied to them for the purpose of verifying the market value. Explanation to Sub-rule (4) provides that the guideline register supplied is intended merely to assist the registering officer to ascertain prima facie whether the market value has been duly set forth in the instrument and it cannot be a substitute for market price and the entries in the guideline register will not foreclose the enquiry of the Collector under Section 47-A of the Act or fetter the discretion of the authorities concerned to satisfy themselves on the reasonableness or otherwise of the value set forth in the documents.