Hon'ble SINHA, J.—Leave granted.

2. Interpretation and/ or application of the provisions of the Indian Stamp Act, 1899 (for short “the Act”) as amended by the State of Tamil Nadu is in question herein.

It arises out of the following factual matrix:

Appellants herein purchased some properties situate in Devala Village, Gudalur Taluk, Nilgiris in the State of Tamil Nadu by a registered deed of sale dated 1.02.1990. Some lands are situated in the State of Kerala also. The details of the lands purchased by them in the State of Tamil Nadu are as under:

Sl. No. Name of the purchaser Survey

No. Extent Doc. No.

and date

1. C.J. Paul, Malapuram 146, 147/2, 2, 3 44.00 Acres 382/90-2.2.90

2. C.P. Jose, Malapuram -do- 44.01 Acres 381/90-2.2.90

3. V.M. Mary, Malapuram -do- 44.00 Acres 383/90-2.2.90

4. C.J. Mathews, Malapuram -do- 44.00 Acres 384/90-2.2.90

3. The Sub – Registrar, Gudalur came to know of the execution of the said deeds of sale on or about 30.03.1996. It initiated a proceeding purported to be under Section 47A (1) of the Act and Section 19B thereof. The proceedings were initiated for collection of deficit stamp duty on or about 5.05.1998 by issuing a letter to the then Collector under the Ac

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