Bhaskar Bhattacharya, CJ.—This is a Reference under Section 54[1A] of the Gujarat Stamp Act, 1958, by which the following four questions have been referred to this Court.

“[A] Whether the order passed by this Hon’ble High Court for demerging the applicant company from his parents company can be considered as reconstructing or amalgamated as per Article 20[d] of the said Act or not.

[B] Whether the applicant has to pay for the change of ownership as per Section 2[g] and Article 20[d] of the Stamp Act or not.

[C] Whether the deponent is entitled to take stamp duty on the share price of appointed date i.e. Rs. 50.05/- on the appointment date Transferor Company transferred the said share to the transferee company? The contention of the applicant is that the share was originally transferred to the transferee company for the face value of Rs. 2/- only or [sic; and not for] Rupees 50.05/-.

[D] Whether the deponent has to consider the market value [Rs. 50.05/-] as per the statement of SEBI or face value [Rs. 2/-] i.e. on the date of appointment date i.e.1st April, 2010.”

2. Brief facts of the case may be narrated thus:

2.1 The applicant is Alembic Pharmaceuticals Limited, a company regis