From a perusal of the inspection report dated 12.2.2004, it is clear that there is no finding recorded by the Sub-Registrar to the effect that the building was in existence prior to the date of the sale deed. On the contrary, the petitioner has taken a specific case before the authorities below that the construction was made after the sale deed was executed. In support thereof, the petitioner had submitted the plan of the architect prepared after the sale deed and also produced her bank pass-book to show that withdrawal to the extent of about Rs.4 lacs had been made by her after the sale deed had been executed, which amount was utilized for the construction on the plot. She also filed her affidavit as well as that of the contractor, in support of her case that the constructions were made after the sale deed was executed. However, the authorities below have relied on the report of the Sub-Registrar and held that there was deficiency in payment of stamp duty, without even recording any specific finding that the constructions were made prior to the execution of the sale deed.It is not the case of the respondents that the land in question was undervalued. An inspection was got done after ten months of the execution of the sale deed. It is also not the case of the respondents that the constructions found on the date of inspection could not have been made within the period which was after the execution of the sale deed and till the date of the inspection. For imposing liability for payment of additional stamp duty, it would be the duty of the respondents to categorically show that there was some concealment made by the petitioner at the time of execution of the sale deed. On mere presumption that constructions existing after nearly a year, must have been existing at the time of execution of the sale deed, stamp duty cannot be imposed after valuing the constructions, without giving a categorical and specific finding that at the time of execution of the sale deed, such constructions had existed. It is settled law that market value, for the purpose of determining the stamp duty, has to be determined with reference to the date on which the document is executed and not on the basis of any improvements made on it thereafter. The Sub-Registrar or the authorities concerned should have verified the same prior to registration of the sale deed or immediately thereafter, but imposing liability for payment of additional stamp duty on the basis of a report submitted after nearly an year of the execution of the sale deed during which period admittedly such constructions could have been made, would not be justified. As such, the orders impugned in this writ petition are based on no sufficient evidence to show that there is any concealment of any material fact on the part of the petitioner or that the petitioner had purchased the plot with constructions. Submit