JUDGMENT

Santosh Hegde, J.-A Deed of Conveyance dated 9.6.1994 executed by a company named ICI India Ltd. in favour of Chand Chhap Fertilizer and Chemicals Ltd. when presented for registration, the concerned Registrar referred the said document under Section 47-A(II) of the Stamp Act to the Collector complaining of the non compliance of Section 27 of the said Act and praying for proper valuation to be made and to collect the stamp duty and penalty payable on the said document. The Collector after inquiry levied a stamp duty of Rs. 37,01,26,832.50 and a penalty of Rs. 30,53,167.50. The said order came to be challenged by the aggrieved party in a revision under Section 56 of the Stamp Act before the Chief Controlling Revenue Authority in Stamp Revision No. 36/95-96 and the said Revisional Authority as per his order dated 4.4.95 partly allowed the challenge and so far as the imposition of penalty was concerned the same was set aside and sightly modified the stamp duty levied by the Collector. Consequent to the order of the Revisional Authority, the appellant herein became liable to pay stamp duty on the said Deed of Conveyance amount to Rs. 36,68,08.887.50. This order of the Revisional