Registration cannot be refused for suspected undervaluation or missing income-tax certificate under the statutory scheme.

A registering officer cannot refuse registration of a sale deed merely because the property is suspected to be undervalued. Section 45A of the Karnataka Stamp Act permits a post-registration reference for determination of market value if undervaluation is suspected, but it does not authorise refusal of registration at the threshold. The text also states that section 230A of the Income-tax Act bars registration only where the document transfers property above the statutory limit and the prescribed certificate is absent; it does not permit the officer to conduct an independent inquiry into actual market value where the deed reflects a lower valuation. On that basis, refusal for non-production of the certificate was unlawful.

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Issues: Whether the registering officer could refuse registration of a sale deed on the ground that the property was undervalued and that a certificate under section 230A of the Income-tax Act, 1961 had not been produced, instead of registering the document and proceeding under section 45A of the Karnataka Stamp Act, 1957.

Analysis: Section 45A of the Karnataka Stamp Act, 1957 permits the registering officer, after registration of the instrument, to refer the document for determination of market value if he has reason to believe that the property has not been truly set forth. That provision does not confer power to decline registration itself on the ground of undervaluation. Section 230A of the Income-tax Act, 1961, being a fiscal provision, had to be construed from its language; it barred registration only where the document purported to transfer property valued at more than the statutory limit and the prescribed certificate had not been produced. On the wording used, the provision did not authorise the registering officer to hold his own inquiry into actual market value where the document showed a lower valuation. In the absence of any governing circular, the officer had no competence to refuse registration solely for want of the section 230A certificate.

Conclusion: The refusal to register the document on the ground of non-production of the certificate under section 230A was unlawful and the challenge succeeded.

Final Conclusion: The impugned refusal to register was set aside and the writ petition was allowed, with a direction to proceed according to law and register the document unless some other legal impediment existed.

Ratio Decidendi: A registering officer cannot refuse registration of an instrument merely on suspected undervaluation or non-production of a section 230A certificate; if undervaluation is suspected, the officer must act within the limited statutory mechanism provided after registration.

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