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22. Thus, the registration of document by the second respondent even though he has reason to believe that the valuation given is not to his satisfaction is perfectly legal and valid.

23. Fraudulent evasion of stamp duty need not be alleged by the second respondent while referring the document to the third respondent to assess the correct stamp duty payable. The Supreme Court in the decision reported in (2008) 8 Supreme 206 (Union of India v. M/s.Dharmendra Textile Processors & Others) held that for imposing penalty under the Income Tax Act, 1961, the revenue need not satisfy the wilful concealment for attracting civil liability, which is required for prosecution, since penalty can be imposed to remedy the loss of revenue. Applying the said principle to the facts of these cases, I hold, the submission made by the learned Senior Counsel is unsustainable.