( 1 ) PETITIONER is a company registered under the Companies Act, 1956. Petitioner has called in question (1) the order passed by the first respondent the Sub- registrar, Yelahanka, Bangalore, dated 1- 4-1998 passed in No. IMP 1/98-99, whereby he has impounded the Deed of Transfer dated 11-3-1998 which had been presented for registration on that day in exercise of his powers under Section 33 of the karnataka Stamp Act, 1957 ('the Act', for short) and has forwarded the same to the district Registrar and Deputy Commissioner of Stamps, Bangalore Urban District, bangalore, the second respondent to this writ petition, for realisation of the deficit stamp duty and other incidental action (copy at Annexure-H), (2) the order dated 21-9- 1998 passed in No. DR : DRI: 1:98-99 (copy at Annexure-K) passed by the second respondent District Registrar and Deputy commissioner of Stamps, Bangalore Urban district, Bangalore, on such reference to him and whereby the second respondent has called upon the petitioner to pay a deficit stamp fees of Rs. 20,42,95,000/- along with a fine of Rs. l,oo,ooo/- as also (3) the order dated 15-4-2000 passed by the third respondent the Chief Controlling Revenue authority and Commissioner of Stamps, in no. SAP:6:98-99 (Copy at Annexure-M) affirming the order passed by the second respondent while exercising revisional powers under Section 53 (1) of the Act in the revision petition that had been preferred by the petitioner.

( 2 ) PETITIONER has sought for quashing of these orders and consequential mandamus to direct the first respondent Registering authority to register the deed of transfer dated 11-3-1998 (copy at Annexure-F) and to return the same to the petitioner after due registration and other incidental reliefs.

( 3 ) THE facts leading to these orders are not in dispute. The subject-matter property, the land, building, structures etc. , which are transferred under the deed of transfer dated 11-3-1998 are all owned by M/s. Larsen and toubro Ltd. , a reputed Engineering Company and who had their independent division known as "construction Equipment manufacturing Business Division" manufacturing engineering construction equipments located at the plot situated on the West side of Bangalore Bellary Road at byatarayanapura village. This entire unit was sought to be sold/transferred -to a new company known as Larsen and Toubro komatsu Ltd. , a Company registered under the Indian Companies Act as mentioned earlier. The terms of transfer are as agreed to between the two companies as per an agreement dated 30-7-1997 (copy at annexure-A ). It is the case of the petitioner that in pursuance of this agreement, a part of the properties of M/s. Larsen and Toubro ltd. , namely the land, building and structures on the factory premises was sought to be transferred and is transferred as per the transfer Deed dated 11 -3-1998. The Transfer Deed makes a reference to the agreement dated 30-7-1997. The Deed of Transfer recites that the transferor conveys the piece and parcel of property being land and building and other structures bearing S. Nos. 88 to 104 of Byatarayanapura village, yelahanka Hobli, Bangalore North Taluk, referred to as the schedule property absolutely in favour of transferee under the deed and that for the purpose of stamp duty and registration, this property is valued at Rs. 59,3l,oo,ooo/ -. The schedule itself reads as under : 'the Schedule above referred to all THAT piece and parcel of non-agricultural industrial land and factory buildings with messuages and tenements standing thereon surrounded by pacca boundary wall, admeasuring in aggregate 67 acres and 10 guntas, situated on the West side of bangalore Bellary Road at Byatarayanapura village in Survey Nos. 88 to 104, Yalahanka hobli, Bangalore North Taluk, measuring 2,72,211 Sq. Mts. bearing the: following descriptions : survey Nos. Extent A-G 88 (part) 1-00 89/1 1. 32 89/2 0. 32 90 5. 35 91 0-35 92/1 0-29 93/1, 2, 3, 4, 5 5-17 94/1