JAGANNATHA SHETTY, J.

( 1 ) THIS is a Reference made by the chief Controlling Revenue Authority under S. 54 of the Karnataka Stamp act, 1957. The matter arises in this way: in March 1975, a coffee plantation at Mudigere Taluk was purchased in the joint names of Mrs. K. Azra jabeen and her brother K. Anwar Ali. In January 1976 they entered into a partnership firm styled as 'kodagibyle estate'. The entire property purchased by them was put into the stock of the partnership firm. In July 1978 the firm was dissolved and a document dated 24th July, 1978 was executed distributing the assets of the firm in-specie as between the two partners. The estate along with building thereon was allotted to the share of the sister while a cash of Rs. 4,80,786 was pa,id to her brother. The Stamp duty on the deed was paid treating it as a deed of partition with an additional stamp duty payable on a deed of dissolution of partnership. When the deed was presented for registration, it was impounded by the Sub-Registrar of mudigere and later referred to the deputy Commissioner under S. 33 of the Stamp Act. On 12th December, 1978, the Deputy Commissioner made an order holding that the document was a conveya

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