( 1 ) THIS reference is at the instance of Kankaria Co-operative Housing Society Ltd. Ahmedabad and the question concerns the liability to stamp duty in respect of eleven sale deeds executed in favour of the said society by a builder who conveyed under twelve separate documents of sale a building with twelve flats built up on Sub-Plot No. 78 of T. P. Scheme No. 4 of Maninagar Final Plot No. 73 admeasuring 840 Sq. yards. The price shown in each one of these documents which we have said earlier is for 1/12th undivided share of the land and the superstructure thereon was Rs 40 500

( 2 ) THE question concerns the exemption claimed by the Co-operative Society from the liability to pay stamp duty on these sales as the purchasers on the basis of a Notification dated 28/03/1968 on eleven out of the twelve documents which were all executed by the same seller to the same purchaser on the same day viz. on 16/03/1973 But even before such documents were finally executed draft of one of-such documents was presented by Shri U. J. Thakore before the Assistant of Superintendent of Stamps Ahmedabad for favour of adjudication under sec. 31 of the Bombay Stamp Act 1958 (Bombay Act No. LX