( 1 ) THIS group of petitions raising identical issues are being disposed of by a common judgment. The simple point urged in support of the petition is whether the Collector while purporting to act under sub-section (4) of Section 47-A inserted in the Stamp Act, 1899 by State legislature has power to impose penalty on the ground that the Stamp Duty paid on the instrument in question was insufficient i. e. instrument is under-valued. So far as this quetion is concerned, the same must be answered in favour of the petitioners in view of the provisions of the Stamp Act as applicable in this State. Sub-section (4) of Section 47-A of the Stamp Act provides :"the Collector may, sue motu, or on a reference from any court or from the Chief Inspector of Stamps, Uttar Pradesh, or any officer of the Stamp Department of the Board of Revenue, within four years from the date of registration of any instrument of conveyance, exchange, gift settlement, award or trust, not already referred to him under sub-section (1) or sub-section (2), call for and examine the instrument for the purpose of satisfying himself as to the correctness of the market value of the property, which is the sub