https://www.taxtmi.com/caselaws?id=297129 A sale certificate issued by a civil court under Order XXI Rule 94 CPC is not an instrument of sale for duty purposes under Section 147 of the Delhi Municipal Corporation Act, 1957. The Court reasoned that "instrument" refers to a document that itself creates or transfers rights, whereas title in an auction sale passes by operation of law only when the sale becomes absolute on confirmation under Order XXI Rule 92 CPC. The certificate merely records the property sold, the purchaser, and the date of finality, so it is evidentiary and declaratory rather than a conveyance. No duty is therefore chargeable on the certificate. en-us Mon, 17 Dec 1990 00:00:00 +0530 Tue, 07 Sep 2021 16:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=297129 A sale certificate issued by a civil court under Order XXI Rule 94 CPC is not an instrument of sale for duty purposes under Section 147 of the Delhi Municipal Corporation Act, 1957. The Court reasoned that "instrument" refers to a document that itself creates or transfers rights, whereas title in an auction sale passes by operation of law only when the sale becomes absolute on confirmation under Order XXI Rule 92 CPC. The certificate merely records the property sold, the purchaser, and the date of finality, so it is evidentiary and declaratory rather than a conveyance. No duty is therefore chargeable on the certificate. Case-Laws Indian Laws Mon, 17 Dec 1990 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=297129