( 1 ) THE questions referred to this Court for its opinion under Section 57 of the Indian Stamp Act by the Board of Revenue (Chief Controlling Revenue Authority) are these: 1. What is the correct classification of the two documents? 2. What is the correct stamp duty on each document

( 2 ) THE facts, which have given rise to this controversy arising in this enquiry, are shortly these. Applicant No. 1 executed a deed of simple mortgage for Rs. 1,00,000 (one lakh) on 6/06/1958 in favour of the Andhra Cotton Company, Secunderabad, paying a stamp duty of Rs. 1,500. 00, Two days thereafter, an agreement was executed by applicant No. 1 in favour of applicant No. 2 appointing the latter as his agent for managing the Ginning and Pressing Factory situated at Adoni, Kurnool District, engrossing this document on a stamp paper of Rs. 37-50 Np. , under Article 6, Schedule 1-A of the Indian Stamp Act. When this document was presented for registration, as the Registration Department had a doubt as to whether this instrument was really governed by Article 6 or whether this document together with the mortgage of 6/06/1958 would constitute a usufructuary mortgage chargeable to duty u