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Supreme Court of India 2020-06-15 allowed

Inspector General of Registration, Tamil Nadu and Ors vs K. Baskaran

Bench: 2 — U.U. Lalit, Hemant Gupta

In Brief

The Supreme Court heard consolidated appeals challenging High Court decisions that had set aside orders by the Inspector General of Registration relating to stamp duty assessments on sale deeds in Tamil Nadu. The appeals raised three key issues: (1) whether directing subordinates to conduct site inspections violated delegation rules; (2) whether a 3-month timeline to determine property market value was mandatory or directory; and (3) whether the appellate authority could enhance assessed property values. The Court held that delegating inspection and information-gathering tasks to officials does not violate rules if the final decision rests with the authority. The 3-month timeline is directory, not mandatory, and a breached timeline should not invalidate proceedings designed to prevent revenue loss through undervaluation. The authority may enhance values in appeals. All High Court decisions were set aside and the appellate authority's orders were restored.

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Stamp Duty Property Valuation Administrative Law Delegation of Powers Procedural Law

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