Judgment M.M. KUMAR, J. 1. This appeal under Clause X of the Letters Patent challenges the view taken by the learned Single Judge in the judgment dated 29.9.2010 in CWP No. 5455 of 2010. 2. The short question raised in this appeal is as to what would be the relevant date for assessment of market value for affixation of stamp duty on the instrument of sale of immovable property. Would it be the date of presentation of the sale deed or would it be the date of allotment. 3. The learned Single Judge has taken the view that the relevant date for assessment of market value of stamp duty to be affixed on the instrument of sale of immovable property would be the date of presentation of the conveyance deed and not any other date anterior to the date of presentation of sale deed nor the one when the immovable property was allotted. The aforesaid view has been taken on the basis of the judgment of Hon'ble the Supreme Court rendered in the case of State of Rajasthan and others v. Khandaka Jain Jewellers, (2007) 14 SCC 339 . The view of Hon'ble the Supreme Court is discernible from the following paras of the judgment: "21. ......Therefore, a taxing statute has to be read as it is. In other words, the literal rule of interpretation applied to it. 22. In this background, if we construe Section 17 read with Section 2(12) then there is no manner of doubt that at the time of registration, the registering authority is under an obligation to ascertain the correct market value at that time, and should not go by the value mentioned in the instrument. xxx xxx xxx xxx 26. Accordingly, we are of the opinion that the view taken by the learned Single Judge as well as by the Division Bench cannot be sustained and the same is set aside. The Collector shall determine the valuation of the instrument on the basis of the market value of the property at the date when the document was tendered by the respondent for registration, and the respondent shall pay the stamp duty charges and surcharge, if any, as assessed by the Collector as per the provisions of the Act. The appeal of the State is allowed. No order as to costs. 4. However, Mr. The appeal of the State is allowed. No order as to costs. 4. However, Mr. Vikas Chatrath, learned counsel for the appellant has placed reliance on Rule 3-B, which has been incorporated by way of an amendment in the year 2010 in the Punjab Stamp (Dealing of Under-valued Instruments) Rules, 1983 (for brevity, 'the Rules'). In order to appreciate the submission made by the learned counsel it would be appropriate to set out Rule 3-B of the Rules, which reads as under:- "3-B - Notwithstanding anything contained in rule 3-A, the rate fixed for allotment or public auction of an immovable property by the Government or a public sector undertaking or a local body, shall be deemed to be the Collector's rate (as fixed under rule 3-A) of such property, and the stamp duty shall be charged for registration of the instruments of such property on the rate, so fixed, at the time of execution of the first conveyance deed; provided it is got registered up to the 30th day of June, 2010, if whole of the payment of such property has been made or within a period of three months from the date of payment of law (last?) installment, as per the schedule, fixed for payment of the allotment or auction price, as the case may be." 5. A perusal of the aforesaid provision makes it abundantly clear that the Rule start with a non-obstente clause and extends one time concession in favour of a classified class of property. The amendment is dated 28.5.2009, which has been notified in the official gazette on 31.3.2010. The Rule further shows that where the allotment of property is made by any Government/Semi-Government organisations, the amount of consideration fixed at the time of allotment of such immovable property or at the time of public auction shall be deemed to be Collector's rate. Accordingly, stamp duty is required to be charged on the amount fixed by the Government-Semi-Government organisation or the auction price, provided the document is registered by the original allottee up to 30.6.2010. A further condition has been provided that the whole of payment of such property has been made or it is to be made within a period of three months from the date of payment of last installment as per the schedule fixed for payment of the allotment or auction price. 6. A further condition has been provided that the whole of payment of such property has been made or it is to be made within a period of three months from the date of payment of last installment as per the schedule fixed for payment of the allotment or auction price. 6. It appears that there was another amendment carried in the year 2009, which has been extended up to 31.3.2010. The amendment became effective from 2.3.2009 and remained operative up to 31.3.2010. The appellant would not be entitled to the benefit of the aforesaid amendment because the document executed in the present case is much before the date of amendment. The document in question was presented for registration before the Sub-Registrar in the year 2006, which is earlier to 2.3.2009. 7. The aforesaid view has been taken by the Letters Patent Bench (of which one of us, M.M. Kumar, J. was a member) in a bunch of appeals including LPA No. 335 of 2011 (Food Corporation of India v. State of Punjab and others, decided on 23.5.2011). In the said appeals similar orders passed by the learned Single Judge were subject matter of challenge. Therefore, we find no substance in the argument raised by Mr. Chatrath. 8. As a sequel to the above discussion, we find no merit in the instant appeal warranting admission and interference of this Court in the view taken by the learned Single Judge. Accordingly, this appeal fails and the same is dismissed. 9. In view of the fact that the appeal has been dismissed on merit, we do not feel the necessity to pass any order on the application seeking condonation of delay of 50 days in filing the appeal.