Revenue passbook is not a title deed where it only reflects record-of-rights entries and the registered instrument remains decisive.

A revenue-issued Pattadar Passbook cum Title Deed that merely reflects entries in the record of rights is not itself the registered title document. Under the Telangana land records framework, the passbook and title deed are intended to evidence recorded rights and assist in proving title or accessing government benefits, but the registered instrument under the Registration Act remains the true document of title. On that basis, the Karnataka AAR held that the document is not classifiable as a document of title under HSN 4907 and instead falls under HSN 4820.

---

---

Issues: Whether the Pattadar Passbook cum Title Deed is a document of title classifiable under HSN 4907 or a passbook classifiable under HSN 4820.

Analysis: The dispute turned on the effect of the Telangana land records framework. The statutory scheme provided for preparation and maintenance of the record of rights, and the passbook and title deed were issued on that basis. The title deed and passbook reflected the entries in the record of rights and were intended to facilitate proof of title and availing of government benefits, but they were not the ultimate title documents. The provisions governing alienation and registration also showed that the registered document under the Registration Act remained the true title document, while the passbook and title deed merely mirrored the legal position recorded by the revenue authorities.

Conclusion: The Pattadar Passbook cum Title Deed is not a document of title under HSN 4907 and is classifiable under HSN 4820.

Ratio Decidendi: A revenue-issued passbook or title deed that only reflects the record of rights and does not itself constitute the registered title document is not classifiable as a document of title under HSN 4907.

---