RAMAPRASADA RAO, J. :- The question referred to us by the Chief Controlling Revenue Authority, Board of Revenue, Madras 5, is as follows-

"Whether in the circumstances and facts of the case the document dated 30-6-1963 (document No. P-37/73 of District Registrar' s Office, Nagarcoil) executed by V. Daniel in favour of the Society of Trustees of Indigenous Churches in India represented by Brother Bakth Singh Chabra styled as a ' release deed' should be termed as a '

conveyance' as defined under S. 2 (10) of the Act attracting stamp duty under Art. 23 of Schedule I of the Stamp Act."

2. By way of prefatory remarks, we make it clear that if the instrument in question which we are asked to interpret is to be understood as a conveyance, then it is not properly stamped, but if it is a release deed as it is styled and understood by the parties, then it has been so properly stamped.

3. For the purpose of establishing a church and incidentally to acquire properties, both moveable and immoveable for the benefit of the said Church, moneys belonging to a religious institution called the Society of Trustees, which at that time was not registered and which was not formed as a society regist