JUDGMENT

R.V. Raveendran, J. —

This appeal relates to the stamp duty payable in regard to a deed of trust dated 9.8.1991 executed by the appellant and his two brothers. The executants paid a stamp duty of Rs. 1,325/ thereon, under Article 64 of Schedule I-B to the Indian Stamp Act, 1899 as amended in U.P. (‘Act’ for short). The registering authority being of the view that it was not duly stamped, impounded it and referred it to the adjudicating authority. The said Authority made an order that the deed also answered the definition of “settlement” as defined under section 2(24) of the Act, and therefore stamp duty was payable under Article 58 of Schedule I-B of the Act on the declared value of the trust property (Rs.2,10,000/-). He directed recovery of deficit stamp duty of Rs.10,225/- and an equal amount as penalty. The said order was challenged by the appellant by filing a revision before the Chief Controller (Board of Revenue), Allahahad. The revisional authority dismissed the revision by order dated 21.5.1996. The appellant challenged the said order in Writ Petition No.54 of 2002. The High Court dismissed the writ petition holding that the authority under the Stamp Act did not comm