( 1 ) THIS matter has come up before us in view of the provisions of Sub-section (2) of Section 57 in Chapter VI of the Indian Stamp Act. 1899, which provides that when the Chief Controlling Revenue Authority refers a case to the High Court, it shall be heard by not less than three Judges.

( 2 ) ON June 6, 1973, there was an agreement between the Bengal Paper Mills Co. , Ltd. , and the West Bengal Industrial Development Corporation Ltd. The agreement related to a loan of Rs. 15,00,000/- which the Corporation granted to the Bengal Paper Mills Co. , Ltd. , The document was stamped with Rs. 1. 50 P, plus a duty of 10 P. as additional duty, it being' agreed between the Corporation and the Company that if on adjudication any further duty was payable the same would be paid by the Company. The Corporation applied to the Collector of Calcutta, for adjudication of the stamp duty payable on the document. The Collector examined the matter. The Collector found that the Company had applied to the Corporation for a loan The Corporation had sanctioned the amount of Rs. 97,28,444. 58p. to the borrower (i. e. the Company) as an interest free loan under the terms and con