Full Judgment
2. On hearing Shri Sarkar, the ld.department representative and perusing the impugned order which has been passed on the ground that the burden cast upon the department to prove under valuation so as to justify loading of the declared value has not been discharged by the Revenue, we hold that prima-facie there is no infirmity in the impugned order so as to warrant any stay. We, therefore, reject the application.