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22. A perusal of sections 31 and 32 of the Act of 1899 reveals that in both the sections there is no provision of appeal, so far as an order under Section 31 of the Act of 1899 is concerned.

23. Section 47-A of the Act of 1899 which is relevant for the present purpose, is being reproduced hereunder :

"47-A. Instruments under-valued, how to be dealt with.--(1) If the Registering Officer, appointed under the Registration Act, 1908 (16 of 1908) while registering any instrument fins that the market value of any property which the subject-matter of such instrument has been set forth less than the minimum value determined in accordance with any rules under this Act, he shall before registering such instrument, refer the same to the Collector for determination of the market value of such property and the proper duty payable thereon.

(1-A). Where the market value as set forth in the instrument is not less than the minimum value determined in accordance with any rules under this Act, and the Registering Officer has reason to believe that the market value has not been truly setforth in the instrument, he shall registere such instrument and thereater refer the same to the Collector for determination of market value of such property an proper duty thereon.

24. A perusal of Section 47-A of the Act of 1899 reflects that if the Registering Officer appointed under the Registration Act, 1908 while registering any instrument finds that the market value of any property which is the subject- matter of such instrument has been set forth less than the minimum value determined in terms of the statutory provisions, he shall refer the instrument to the Collector for determination of the market value of such property to be payable.

25. As per Section 47-A(1-A) of the Act of 1899 where the Registering Officer is of the view, that the market value as set forth is not less than the minimum value and the Registering Officer has reason to believe that the market value has not been truly set forth, he can refer to the same to the Collector for determination. The Collector upon receipt of the reference after extending opportunity of hearing to the parties, determines the market value of the property and the difference, if any, and the amount of duty shall be payable by the person liable to pay the duty.