( 1 ) THE document marked P-2 executed in 1968 was presented for registration before the Sub-Registrar , Bhimavaram on 7. 3. 1968 by the executants. The document calls itself a sale deed. It is drawn up on stamp papers of value of Rs. 6,525. 00. The Sub-Registrar, Bhimavaram, before whom this document was presented for registration entertained a doubt about the exact stamp duty payable on the document. He therefore made a reference to the District Registrar of Assurances, Eluru. The district registers held that the said document to be a sale for consideration of Rs. 1,44,444. 44 chargeable with a stamp duty of Rs. 6,525. 00 under Art. 20 of Schedule 1-A of the Indian Stamp act. He was also of the opinion that a transfer duty of Rs. 7,222. 20 is payable under Section 120 of the Andhra Pradesh Municipalities act, 1965.

( 2 ) AS the document was insufficiently stamped it was impounded by the Sub-Registrar and the District Registrar, Eluru, as Collector levied deficit stamp duty of Rs. 7,199. 70 and a penalty of Rs. 50. 30.

( 3 ) AGGRIEVED by that order Kottu Kanna rao, the purchaser preferred a revision petition to the Board of Revenue under section 56 (1) of the Indian