Finality of Section 47-A adjudication: Collector cannot reopen a completed stamp duty determination without express statutory review power.

A quasi-judicial determination under Section 47-A of the Stamp Act attains finality once the parties are heard and the market value and proper stamp duty are decided. In the absence of an express statutory provision, the Collector cannot reopen, review, or cancel that completed adjudication merely because a later objection or higher offer is made, and no inherent review power can be assumed. As the original reference had already concluded that the sale consideration reflected the true value, the later cancelling order and the consequential demand for additional duty and penalty were without jurisdiction and were liable to be quashed.

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Issues: Whether the Collector acting under Section 47-A of the Stamp Act had power to reopen and review a completed adjudication determining the market value of the property and the proper stamp duty payable.

Analysis: The reference under Section 47-A had already been determined after hearing the parties, and the authority had concluded that the sale consideration represented the true value. The later order cancelling that determination disclosed no statutory basis, no allegation of fraud or misrepresentation, and no provision conferring review power. Proceedings under Section 47-A are quasi-judicial, and a quasi-judicial order cannot be reopened merely because another objection or higher offer is later presented. In the absence of an express provision, the power of review cannot be assumed, and the consequence-based order imposing additional duty and penalty could not stand once the foundational reopening was unauthorized.

Conclusion: The Collector had no power to review or reopen the earlier order under Section 47-A of the Stamp Act. The cancelling order and the consequential demand of additional stamp duty and penalty were without jurisdiction and liable to be quashed.

Ratio Decidendi: A quasi-judicial determination under Section 47-A of the Stamp Act attains finality and cannot be reopened or reviewed unless the statute expressly confers such power.

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