( 1 ) CHALLENGE in this group of petitions is to the action of the respondent-authority of demanding stamp duty on the letter of allotments and / or such documents issued by the petitioner-Society to its Members, as conveyance, under the provisions of the Bombay Stamp Act, 1958 [for short, "the Stamp Act"].

( 2 ) THE petitioners herein are the co-operative housing societies duly registered under the provisions of the Gujarat Co-operative Societies Act, 1961 [for short, "the Act"]. For the purpose of providing residential accommodation to its members, the petitioner-societies purchased lands and thereafter, applied and received development permission from the competent authority for the construction of residential units. Pursuant thereto, the petitioner-societies carried out the construction.

2. 1 It is the case of the petitioners that on inquiry by them, they were told by the respondent-authority that they will have to pay stamp duty on the letters of allotment issued by the petitioner-societies to its members as a 'conveyance' under the provisions of the Stamp Act read with the Schedule thereto. 2. 2 Being aggrieved by the said demand, the present petitions have been filed.

( 3 ) M

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