JUDGMENT :

ARAVIND KUMAR, J.

1. These stamp references are made under Section 54(1A) of the Gujarat Stamp Act, 1958 (hereinafter referred to as ‘the Stamp Act’) by the Chief Controlling Revenue Authority, Gujarat State, Gandhinagar for the opinion of this Court.

2. Though questions of law in each of this stamp reference would overlap, the facts in each case and would differ partially and as such, the facts are narrated independently and the questions of law are dealt with collectively.

RE: STAMP REFERENCE No. 1 OF 2020

3. A scheme of amalgamation between Holcim (India) Private Limited with Ambuja Cement Limited was presented before this Court for sanctioning the said scheme. The said scheme came to be sanctioned by the Company Court i.e. High Court of Gujarat on 18.3.2014 and pursuant to the same, the applicant – Ambuja Cement Limited filed an application dated 15.5.2014 before the Collector under provisions of Section 31(1) of the Stamp Act seeking opinion as to proper stamp duty leviable on the order of sanction of the scheme by the Company Court. The Collector, by order dated 26.