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16. Dealing with the similar subject as to the determination of market value, in the decision reported in 2009 (1) CTC 698 (Ezhilarasi Vs. The Inspector General of Registration), this Court held that the onus is on the Department to establish that the market value of the property has not been truly set forth and that the market value as claimed by the Department is contemporaneous to the document tendered for registration. Referring to the decisions of the Apex Court as well as to the decisions of this Court, this Court held that where there is a doubt that the market value has not been truly set forth in the instrument, the guideline value is only a prima facie guide for ascertaining the market value. The Department will have to go by the various parameters set down in the rules for determination of the market value if they have a reasonable belief that the market value of the property has not been truly set forth in the document. In the context of the said decisions, when there are no material to suggest that the property had been undervalued and that the value of the property fixed not being based on any acceptable material, I have no hesitation in accepting the case of the appellant herein that the order of the first respondent did not have any basis to arrive at the value of Rs.355/- per sq.ft. The mere fact that the appellant is in the field of real estate and that the potential of the property for further development or that it is adjacent to the multi-storeyed building, by itself, does not decide on the issue that the value of the property has been understated in the instrument. Hence, having thus noted the physical features of the property, there being no basis indicated either in the order of the second respondent, or for that matter, even in the first respondent's order for arriving at a satisfaction that the value stated in the document is untrue, the assumption of jurisdiction under Section 47-A of the Indian Stamp Act is totally without any basis. Consequently, the adoption of Rs.355/- per sq.ft. as the market value is without any basis. It must be noted that a mere fact of difference in value stated in the instrument and the market value, per se, does not justify the invoking of the provisions under Section 47-A of the Indian Stamp Act, that only if and when the authorities have a reasonable belief that the market value of the property has not been truly set forth in the document that the Registering Officer, after registration the document, may refer the same to the Collector for determination of the market value of the property. Thereupon, as per Section 47-A(2) of the Indian Stamp Act, the Collector holds an enquiry as prescribed under the rules and determine the market value of the property . Thus in all cases of Section 47-A proceedings, law requires that there are prima facie materials at the hands of the registering authority to form an opinion as to the market value not truly set forth in the instrument and this leads to an enquiry and a final order passed depending on the outcome of the enquiry. The invokiing of the jurisdiction on a sheer difference in price stated in the instrument with the market price, would only make the exercise an automatic and ritualistic exercise opposed to the very scheme of the provisions of Section 47-A of the Indian Stamp Act.