HIMALAYA HOUSE CO. LTD. BOMBAY vs CHIEF CONTROLLING REVENUE AUTHORITY

The Supreme Court held that under Article 23 of the Indian Stamp Act, 1899, the Revenue authorities are not empowered to independently assess the value of consideration in a document. The Court clarified that the mere reference to earlier agreements in a deed does not incorporate their terms unless there is clear intent from the parties. It was determined that the consideration stated as nil in the deed was not binding, and the Revenue could assess the duty based on the total amount payable by assignees, thus allowing the appeal.