Stamp duty is confined to the deed itself; earlier agreements cannot enlarge consideration absent clear incorporation.

Consideration under an assignment deed must be ascertained from the instrument itself, read as a whole, and earlier agreements are not incorporated unless the deed clearly shows that intention. A mere reference in the preamble does not enlarge the stated consideration. For stamp duty, the revenue cannot conduct an independent valuation of the assigned rights where the instrument discloses the basis of charge. The deed therefore remained chargeable on the basis stated in it, namely no consideration.

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Issues: Whether the consideration for the assignment deed could be determined by looking beyond the terms of the instrument and by treating earlier agreements as incorporated into it, and whether the revenue could independently assess the value of the rights assigned for stamp duty purposes.

Analysis: The assignment deed stated that the transfer was made for no consideration. A mere reference in its preamble to earlier transactions did not incorporate the terms of those transactions into the deed. For stamp duty under the charging article, the consideration must be gathered from the instrument itself, read as a whole, unless the document clearly shows an intention to incorporate extraneous terms. The Stamp Act did not confer power on the revenue to make an independent inquiry into market value where the instrument itself disclosed the basis of charge. The statutory obligation to set forth consideration and relevant facts fully and truly did not authorise the revenue to rewrite the document or to assess duty on a valuation outside the instrument.

Conclusion: The consideration could not be enlarged by reference to the earlier agreements, and the revenue had no authority to independently value the assigned rights. The deed was chargeable on the basis stated in the instrument, namely no consideration.

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