1.This writ petition is directed against the order passed on 21-7-2009 by the Collector under Section 41-A of the Indian Stamp Act, 1899 and District Registrar, Hyderabad (South), directing the writ petitioner to pay a sum of Rs.95,545/-, towards the deficit stamp duty in respect of two documents bearing No. 80/2002 and 713/2002, and also the orders passed by the Chief Controlling Revenue Authority and Commissioner & Inspector General of Registration and Stamps, Andhra Pradesh, Hyderabad, through his proceedings dated 20-7-2010, rejecting the Appeal preferred by the petitioner against the aforementioned orders passed by the Collector.

2. One Sri G. Visweswara Rao. the husband of the petitioner, acquired house property bearing municipal No.8-3-315/C/5, admeasuring 253 square yards or 211.54 square meters, situate at Maruthinagar. Yousufguda, Hyderabad, under a registered sale deed bearing document No.3458/1974. Sri G. Visweswara Rao died intestate on 26-6-2001, leaving behind his wife, the petitioner herein, two sons and two daughters, namely, Smt. G. S. R. Lakshmi. Sri G. V. S. Sai Kumar. Smt. N. P. Padmaja and Sri. G. Subba Rao. Thus, the petitioner herein and her four children, referred to supra, succeeded to the estate of Sri. Visweswara Rao. On 7-1-2002, Sr. G. V. S. Sai Kumar, Smt. N. P. Padmaja and Sri. G. Subba Rao, joined together and executed a release deed bearing No.80/2001 in favour of the writ petitioner herein releasing and relinquishing their 3/5th undivided share in house property bearing municipal No.8-3-315/C/5. Maruthinagar, Yousufguda, Hyderabad, for a total consideration of Rs.1,50,000/-. The said release deed is appropriately stamped and it was also registered by the Sub Registrar concerned. Subsequently, Smt. G. S. R. Lakshmi, executed another release deed on 31-1-2002 in favour of the petitioner herein releasing and relinquishing her 1/5th undivided share in the same property referred to supra for a total consideration of Rs.50,000/-. The said document bearing No.713/2002 was also registered by the Sub Registrar concerned. Both these documents have been released to the petitioner.

3. Long thereafter, on 28-2-2007, the Collector, exercising the power available under Section 41 - A of the Indian Stamp Act 1899, has issued a notice on the ground that during the audit undertaken by the Accountant General, while checking the documents registered in the Sub Registrar Office. Banjara Hills, it is realized that in respect of both the documents bearing Nos.80/2002 and 713/2002, to which the petitioner herein is a party, stamp duty of Rs.21,500/- and Rs.7,155/- respectively is only paid, whereas both these documents are liable to be treated as conveyance deeds on sale and consequently, a deficit stamp duty of Rs.95,545/-is payable and hence, called upon the petitioner to show cause why the said amount should not be recovered from her. On the plea that the writ petitioner has not shown any cause, the Collector passed final orders on 21-7-2009, confirming his provisional conclusion about the deficit stamp duty on the aforementioned two documents and thus, demanded payment of Rs.95.545/-, within a period of 30 days from the date of receipt of the said order. The petitioner carried the matter in Appeal before the Chief Controlling Revenue Authority & Commissioner and Inspector General of Registration and Stamps, who rejected the said Appeal, based upon the ratio laid down by this Court in K. V. Subba Rao versus District Registrar of Assurance, Guntur, AIR 1986 AP42 and Maddula Girish Kumar and another versus The Commissioner of Survey, Settlements and Land Records and another, 1993 (1) A. P. L. J. 79. Hence, this writ petition.

4. Heard Sri. J. V. Rao, the learned counsel for the petitioner as well as the learned Government Pleader for Revenue.

5. It is contended by Sri. J. V. Rao that the Collector as well as the Chief Controlling Revenue Authority have misconstrued completely the ratio laid down by th