A.P. Shah, C.J.

The interpretation and application of the Samadhan Scheme introduced by the Tamil Nadu Government in G.O.Ms.No.193, Commercial Taxes Department, dated 27.12.2004 falls for our consideration in these appeals arising out of the common judgment and order passed by the learned single Judge dated 29.4.2005 whereby it was held that the said Scheme would apply to proceedings pending at the appellate stage also, and it is not restricted only to proceedings pending before the original authority.

2. The brief facts necessary to decide these appeals are as under:

By the aforesaid Government Order, the Tamil Nadu Government took into consideration the arrears of stamp duty payable on deeds of sale, exchange, gift, etc., and had thought it fit to introduce the Samadhan Scheme under the Government Order. The respondents in these appeals, though they have suffered orders against them by the original authority, have filed appeals and the appeals were pending when the Samadhan Scheme was introduced. The Competent Authority denied the benefit of the Samadhan Scheme to the respondents on the ground that the Scheme will be applicable only to proceedings pending before the ori