CHIEF CONTROLLING REVENUE AUTHORITY vs COSTAL GUJARAT POWER LTD. .

The Supreme Court upheld the Gujarat High Court's decision that Coastal Gujarat Power Ltd. was not liable to pay additional stamp duty of Rs. 50,41,600/- on the 'Indenture of Mortgage for Delayed After Assets Deed' registered under the Gujarat Stamp Act, 1958. The Court clarified that the liability for stamp duty arises from the nature of the instrument and not the perceived legislative intent behind Section 5 of the Act. The ruling emphasized that the State cannot impose additional duties beyond what is stipulated in the Act, affirming the High Court's interpretation of Sections 5, 3(a), 3(B), and the relevant Articles of Schedule 1.