1. The deed of conveyance executed by the Respondent for consideration of Rs. 3,500/- was stamped for. purpose of stamp duty under Art.21 of the Kerala Stamp Act, on the amount or value of the consideration at the rate specified in the Article. On objection being taken, to the sufficiency of the stamp duty, the Collector held that stamp duty had to be levied on the market-value of the property as assessed by the Tahsildar in his report, viz., Rs. 48,000/-. The Respondent preferred an appeal to the District Court under S.45-A Clause (4) of the Act. The District Court took the view that the Collector's action was unjustified and his order was unsustainable having regard to the provisions in the Stamp Act. This view of the District Judge has been canvassed in this revision petition.

2. We may usefully extract Art.21, 22, 29 and 31 of the Stamp Act, which read as follows:

"21. Conveyance as defined by S.2 (d), other Five rupees for every Rs. 100 than a conveyance specified in No. 22, not being a trans- or part thereof of the amount fer charged or exempted under No. 55. or value of the consideration for such conveyance.

22. Conveyance (as defined by S.2 (d). not being Seven rup