Two appeals have been filed by the petitioners challenging the order of the first respondent upholding the order of the second respondent.

2. The brief facts are- as follows: C.M.A.No.2418 of 2008:-

(i) The appellant Ezhilarasi purchased 0.68 cents of agricultural land in Chidambaram Town, Ward No.4, Block No.6, T.S.No.555 at the rate of Rs.6.75 per square foot = Rs.2,943/- per cent. The document was executed on 14. 1998 and presented on the same date (i.e.) on 14. 1998. It was registered as document No.484/2001 on 3. 2001. The value as per the instrument was Rs.2,00,000/-.

(ii) The respondent Department was of the view that the appellant has not set forth the true market value of the property in the instrument. Therefore, proceedings were initiated under Section 47A of the Indian Stamps Act read with Tamil Nadu Stamps (Prevention of Undervaluation of Instrument) Rules 1968 (herein after referred to as The Act and The Rules). Form-I notice was issued on 19. 2001 in C.P.No.2644/2001-02. The Department initially contended that the guideline value was Rs.253.50 per square foot. Appellant submitted her objections to the Special Deputy Collector (Stamps) and pleaded that the