This petition impugns the orders dated 15 September 1997 passed by the Collector Stamps as well as the order dated 29 March 2003 in terms of which the Chief Controlling Revenue Authority has affirmed the order of the Collector holding the petitioner liable to pay additional stamp duty. The issue itself arises out of execution of a Power of Attorney on 12 December 1994 by the father of the petitioner. As is evident from a reading of that instrument, the father of the petitioner who was 77 years of age on the date of its execution conferred rights upon the petitioner to manage his properties as well as to enter into transactions of sale in respect thereof. It appears that the aforesaid Power of Attorney fell for scrutiny with the respondents taking the position that it amounted to a sale of the property in question. Accordingly, the Collector Stamps by his order of 15 September 1997 subjected the Power of Attorney to additional stamp duty. However, as is evident from the disclosures made in the writ petition itself and which facts were also raised by the petitioner in her objections and revision, the Power of Attorney executed on 12 December 1994 was cancelled on 2 December 1996. The cancellation was brought about by way of a registered instrument executed and details thereof have been set forth in paragraph 15 of the writ petition. It has also come on the record that subsequently the father of
