In Brief
This case concerns the validation and stamp duty assessment of two sale deeds with allegedly undervalued property considerations. The Supreme Court affirmed the High Court's decision, holding that a Registering Officer cannot refer documents to the Collector for market value determination without recording prima facie reasons for believing undervaluation. The Court ruled that 'reason to believe' requires objective evidence, not mechanical reference. The Collector must follow strict procedural rules: issuing Form-I notice with reasons, passing a provisional order with clear basis, issuing Form-II for representations, and then a final order. The department bears the onus to prove undervaluation satisfactorily through material evidence. The appeals were dismissed as procedural compliance was violated and no proper basis was established for the value enhancement orders."
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