N.V. Balasubramanian, J.

1. The Chief Controlling Revenue Authority (Stamp Act) has made a reference under Section 57(1) of the Indian Stamp Act, 1899 and sought a clarification regarding classification of the document in question and chargeability to stamp duty.

2. There is a firm, by name, M/s. Lakshmi Spinners constituted under the Indian Partnership Act, 1932 and M/s. Sampurna Spinning Mills Ltd. was admitted as a partner on 22.10.1986 and the profit sharing ration as well as capital investment was arrived at as under:-

Tmt. Sarojini Muthusamy 25% Rs. 1,81,250.00 Tmt. Vasantha Valayutham 25% Rs. 1,81,250.00 Tmt. Mallammal 20% Rs.1,45,000.00 Tmt. Amirtham 10% Rs.72,500.00 M/s. Sampurna Spinning Mills 20% Rs.1,45,000.00 The partners have decided to dissolve the firm on 12.11.1986 and the properties were shared as under:

1. Sampurna Spinning Mills Rs.15,59,600

2. Tmt. Sarojini Muthusamy Rs. 18,800

3. Tmt. Vasantha Valayutham Rs. 18,800

4. Tmt. Mallammal Rs. 15,400

5. Tmt. Amirtham Rs. 7,800

6. The Registering Authority was of the opinion that the assets were not divided at the agreed ration as per section 48 of the Indian Partnership Act and the deed of dissoluti