Revisional power under the Stamp Act survives endorsement, and Section 32 does not create finality for the Collector's duty determination.

The legal fiction in Section 32(3) of the Indian Stamp Act, 1899 is limited to treating the instrument as duly stamped and receivable in evidence; it does not make the Collector's endorsement final or bar further scrutiny. Section 31 empowers the Collector to determine the duty chargeable, and Section 56(4) confers revisional power on the Chief Controlling Revenue Authority to examine that determination on its own motion or on application. In the absence of an express finality clause in Section 32, the Collector's endorsement does not oust revision, and the revisional authority may review the stamp duty assessment notwithstanding the endorsement.

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Issues: Whether the Board of Revenue had revisional jurisdiction under Section 56(4) of the Indian Stamp Act, 1899 to examine the Collector's determination of stamp duty after an endorsement had been made under Section 32 of the Act, and whether the legal fiction in Section 32(3) conferred finality on such endorsement.

Analysis: Section 31 confers the power on the Collector to determine the duty chargeable on an instrument, while Section 32 deals only with the consequences of that determination by requiring endorsement and by creating a legal fiction limited to the instrument being treated as duly stamped and receivable in evidence. The legal fiction in Section 32(3) does not make the Collector's endorsement final or binding. Section 56(4), as inserted by the State amendment, confers a revisional power on the Chief Controlling Revenue Authority on its own motion or on the application of any party to satisfy itself as to the amount with which an instrument is chargeable. The absence of an express finality clause in Section 32 means that acceptance of the Collector's order and issuance of endorsement do not bar revision. The revisional power extends to the Collector's order determining stamp duty, irrespective of whether endorsement under Section 32 has followed.

Conclusion: The Board of Revenue had jurisdiction to entertain the revision and the endorsement under Section 32 did not oust revisional scrutiny under Section 56(4).

Final Conclusion: The appeal failed because the revisional power over the Collector's determination of stamp duty remained available notwithstanding the certificate issued under Section 32.

Ratio Decidendi: A legal fiction created for a limited statutory purpose cannot be extended to create finality where the statute confers a revisional power and contains no finality clause.

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