Stamp duty valuation must rest on relevant material and fair inquiry, not speculative assumptions about property value.

For stamp duty valuation, market value must rest on relevant material and a fair, rational inquiry. Speculative assumptions about locality and rental value are insufficient where the property is a small house in a non-metropolitan town, and the assessment must also consider factors such as the age of the building, quality of construction, and comparable instances. The article notes that the higher valuation, together with the consequential demand for additional stamp duty and penalty, could not be sustained because the revenue's approach was casual, arbitrary, and unsupported by adequate factual basis.

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Issues: Whether the determination of market value for the purpose of stamp duty under Section 47-A of the Stamp Act and the relevant Stamp Rules was based on sufficient material and could be sustained.

Analysis: The valuation adopted by the revenue authorities was found to be unsupported by adequate material. The property was a small house in a non-metropolitan town, and the authorities relied on speculative assumptions about locality and rental value without properly considering the age of the building, the quality of construction, or comparable instances. The minimum market value prescribed under the rules was not treated as conclusive, but the higher valuation still had to rest on a fair and rational inquiry. The method adopted was held to be casual, arbitrary, and devoid of constructive material.

Conclusion: The valuation and the consequential demand for additional stamp duty and penalty could not be sustained, and the appeal succeeded.

Ratio Decidendi: A valuation made for stamp duty purposes under Section 47-A must be founded on relevant material and a fair inquiry; an arbitrary or assumptive assessment without proper factual basis is liable to be set aside.

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