Stamp duty valuation turns on the sale deed's execution and registration date, not the earlier agreement to sell.

Stamp duty on a sale deed executed pursuant to a decree for specific performance is assessable by reference to the market value prevailing on the date the sale deed is executed and tendered for registration, because stamping provisions require the instrument to be complete and duly stamped at execution. A sale deed is legally distinct from the earlier agreement to sell, and the valuation cannot be fixed by the agreement date or by the pendency of the suit. Litigation delay and hardship do not alter the strict construction of the taxing statute. The reassessment of stamp duty was upheld and the contrary view was set aside.

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Issues: Whether stamp duty on a sale deed executed pursuant to a decree for specific performance is to be assessed on the market value prevailing on the date of the agreement to sell or on the date when the sale deed is executed and tendered for registration.

Analysis: The provisions governing execution and stamping of instruments require the instrument to be complete and stamped at the time of execution. A sale deed is distinct from an agreement to sell, and the charging and inquiry provisions do not make the valuation depend on the date of the prior agreement or on the date of the suit. Under the stamp law, the registering authority may examine undervaluation and refer the matter for determination of market value, and the relevant point of time is the execution and presentation of the sale deed for registration. Considerations of hardship caused by litigation delay cannot control the interpretation of a taxing statute, which must be construed strictly according to its language.

Conclusion: The correct market value is that prevailing on the date when the sale deed is tendered for registration, not on the date of the agreement to sell. The challenge to the reassessment of stamp duty fails.

Final Conclusion: The impugned view of the High Court was set aside, and the registering authority and Collector were held entitled to assess stamp duty on the basis of the market value at the time of execution and registration of the sale deed.

Ratio Decidendi: For stamp-duty purposes, the decisive date for valuing an instrument of sale is the date of execution and tender for registration of the sale deed, and not the date of the earlier agreement to sell or the pendency of litigation.

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