( 1 ) THIS petition challenges a determination made by the Collector under sec. 31 of the Bombay Stamp Act 1958 The determination came to be made by the Collector under the following circumstances. The first and second petitioners owned a piece of land admeasuring 55 square yards situate at Lal Darwaja in the City of Ahmedabad. They agreed to grant a lease of the said piece of land to the third petitioner on the terms and conditions contained in a draft indenture of lease which was agreed upon between the parties. The third petitioner brought the draft indenture or lease to the Collector and applied to have the opinion of the Collector as to the duty with which it was chargeable under sec. 31 of the Bombay Stamp Act 1958 This application was made on 20th June 1961 and was accompanied by the requisite fee directed by the Collector. On receipt of the application it appears the Collector felt doubt as to the amount of duty with which the draft indenture of lease was chargeable and he accordingly drew up a statement of the case and referred it with his own opinion thereon for the decision of the Inspector General of Registration who is the Chief Controlling Revenue Au