Satish Chandra, J. - (1.)THE Board of Revenue has submitted this statement of the case with a reference under Section 57 (1) (a) of the Indian Stamp Act.
(2.)ON 22nd March, 1966, the Can tonment Board Ranikhet, executed an inden ture stating that in consideration of the purchase money of Rs. 7, 525/- the Board ad sold the right of collection of resin from the M. E. O. forests out of channels to be tapped during the year 1966. The tapping is to be started from 1st April, 1966 and is to be completed by 15th October, 1966. Tulsa Singh, Bahadur Singh and Jaint Singh, the purchasers, were to deposit Rupees 5, 643.50 P. upto 22nd July, 1966 and the balance Rs. 1, 881.50 P. on or before the 15th August, 1966. The document was signed by the Vice-President of the Canton ment Board as well as the three purchasers. It was attested by two witnesses.
A similar indenture was executed by the Board on 6th June, 1966 in favour of the same three persons. Under it, in consi deration of the purchase money of Rupees 32, 175/- the Board sold the right of collec tion of resin from the Cantonment forests out of channels to be tapped during the year 1966 to the same three purchasers. Rupees 16, 088/- were to be deposited upto 7-4-1966 and the balance in two equal instal ments of Rs. 8, 043.50 P. on or before 15th June, 1966 and 15th August 1966. This document was also signed by the Vice-President on behalf of the Board and by the three purchasers. It was attest ed by two witnesses. In this indenture, the purchasers were to start tapping from 1st March, 1966 and were required to complete it by the 15th October, 1966. Both the documents contained identical other terms as to penalty, fines, forfeiture, the method of collection and removal of resin etc. etc.

(3.)TULSA Singh, one of the purcha sers, presented the two documents before the Collector, Almora for adjudication of Stamp duty. The Collector in his turn re ferred the matter to the Board of Revenue for appropriate orders under Section 56 (2) of the Stamp Act.