ORDER :- This revision arises out of proceedings under the Stamp Act, 1899, for under-valuation of an instrument of conveyance for purposes of stamp duty. The conveyance was executed under an instrument dated 24-9-1976. The vendor is a public limited company by name Nonsuch Tea Estates Ltd., Conoor (herein after called 'Nonsuch'). The purchaser is a private limited company, by name, Mahavir Plantations Pte, Ltd., (hereinafter called 'Mahavir'). The subject matter of the conveyance comprised three tea estates by name Prospect Estate, Liddledale Estate and Seaforth Estate. Although the transaction covered the entire plantations in all the three estates, as going concerns, the document was executed only in respect of the lands as such and other items of immovable property. The lands conveyed under the instrument were of the total extent of 6029-76-1/2 acres. Of this extent, Prospect and Liddledale estates covered 3508.83-1/2 acres; the Seaforth estate covered 2520.93 acres. The total consideration set forth in the instrument, and that was also claimed to be the market value, for the three estates of the aggregate extent of 6029.76-1/2 acres was Rs. 1,05,47,955. A stamp duty o