( 1 ) THIS is a case by Chief Controlling Revenue Authority under S. 54 of the Karnataka Stamp Act, 1957 (hereinafter called the 'stamp Act' ).

( 2 ) THE essential facts of the case leading up to this case are as follows :- the petitioner herein which is a company registered under the Companies Act, 1956, agreed to take over a Tea Estate known as 'glenlorna Tea Estate' comprised in different Survey Nos. situate in Poradu Village, T. Shettigeri Village and Nemmale village of Virajpet Taluk, Kodagu District and measuring in all 942. 56 Acres. The said Tea Estate is leasehold granted by Government of Coorg under two lease deeds dated 1913-1914 and 1915-1916, for a period of 999 years. The property passed different hands and Coorg Tea Company Limited acquired leasehold right in the said Tea Estate and agreed to convey leasehold rights to the petitioner in the said Tea Estate for a consideration of Rs. 1,36,25,000/ -. Being doubtful about the stamp duty to be paid on the said conveyance, the petitioner addressed a letter to the District Registrar of Kodagu, Mercara on 21-5-1985 under S. 31 of the Stamp Act and the District Registrar conveyed by his communication dated