has referred the matter to the respondent no.3 only after registration of the sale deed on 04.07.2022, hence the said reference was/is itself bad in law, thus the order dated 26.08.2022, passed by the respondent No.3, in Stamp Case No.32 of 2022, directing the petitioner to pay a sum of Rs. 65,99,900/- on the head of deficit stamp duty, being perverse, illegal and contrary to law, ought to have been simply quashed by the learned Court of Divisional Commissioner, Purnea Division, Purnea and he should have refrained from referring the matter to the Collector, Araria, since there is no provision under the Act, 1899, which permits reference of a matter regarding determination of deficit stamp duty, after the sale deed has been registered, and the only remedy available to the respondents is under Section 47-A(3) of the Act, 1899, whereunder the Collector is empowered to suo motu , within two years from the date of registration of such instrument, not already referred to him under Section 47-A (1), examine the instrument as also determine the market value of such property and accordingly, determine the deficit stamp duty required to be paid by the person liable to pay the same. However, in the present case, the Collector has till date not invoked/exercised his suo motu powers, as provided for under Section 47-A (3) of the
