1. This appeal is against the order of the Inspector General of Registration dated 07.04.2004. The appellant herein is the purchaser of a property from TANSIDCO, a Government of Tamil Nadu Undertaking, in the Industrial Estate, Ambattur. The area purchased is of an extent of 0.1402 acres.

2. It is seen from the facts herein that the appellant herein was allotted a work shed by the Tamil Nadu Small Industries Development Corporation Limited, fixing the price of Shed No.74 at Rs.6,43,290/- and Work Shed No.474 at a price of Rs.6,83,750/-. The proceedings dated 30.12.1992 and 07.07.1993 respectively in respect of the above-mentioned allotment of sheds, directed the appellant herein to make an initial payment as ordered therein and the balance of amount, in terms of the proceedings given therein. It is seen from the proceedings dated 07.07.1993 of SIDCO that as against Rs.6,83,750/-, the appellant had paid a sum of Rs.6,88,950/-. The proceedings dated 07.07.1993 recorded that the excess amount of Rs.5,200/- would be refunded to the appellant herein. The proceedings further pointed out that the sale deed and memorandum of understanding had to be executed before taking possession of the shed through the authorised officer. Admittedly, in terms of the allotment, a sale deed was also executed. By proceedings dated 06.12.2001, TANSIDCO addressed a letter to the Sub Registrar, Ambattur, to register the document and brought to their attention that under G.O.Ms.No.64 dated 19.2.1996, the Government of Tamil Nadu permitted registration of the document at the value fixed under the sale deed irrespective of the market value prevailing at the time of registration.

3. G.O.Ms.No.64, Commercial Taxes and Religious Endowments Department dated 19.2.1996 notified that in respect of industrial plots and sheds allotted by SIPCOT to industrial entrepreneurs, the registration fee on sale deeds and mortgage deeds should be collected on the value determined by SIDCO. G.O.Ms.No.48, Commercial Taxes, dated 06.03.2000 notified the Governments remission of stamp duty in respect of instruments executed between 25.1.2000 and 24.1.2001 relating to sale, lease and lease-cum sale of the industrial plots and industrial sheds in backward and most backward blocks notified in G.O.Ms.No.41, Industries (MIG 2) Department dated 18.03.1996 by the Tamil Nadu Small Industries Development Corporation (SIDCO), State Industries Promotion Corporation of Tamil Nadu Ltd. (SIPCOT), Tamil Nadu Corporation for Industrial Infrastructure Development Limited (TACID) and the industrial estates formed with the assistance of the Government and registered under the Companies Act, 1956 or under the Tamil Nadu Cooperative Societies Act, 1983.

4. By notice dated 28.01.2002, the Special Deputy Tahsildar called upon the appellant herein to produce the necessary details as to the declaration of the contracted value of the property. The notice under Form I issued under Section 4 was sent to the appellant herein on the premise that as against the value mentioned in the document at Rs.6,51,190/-, the value as per the guideline register was Rs.33,12,683/-. Hence, adopting the said value, the notice called upon the claimant/appellant herein to remit the differential stamp duty at Rs.3,46,125/-.

5. The appellant herein wrote a letter dated 26.06.2002 and objected to the proceedings, contending that the proposal had ignored G.O.Ms.No.64 dated 18.2.1996. In the circumstances, they requested the first respondent to accept the value as shown in the document. They also relied on the decision reported in 2002 (2) CTC 329 (R.Sukumaran Vs. State of Tamil Nadu) that the sale being by a statutory body, the value as given in the instrument be accepted.

6. The first respondent passed an order dated 22.07.2002 holding that the document presented for registration was an outright purchase and as such, G.O.Ms.64 dated 19.2.1996 had no relevance to the appellant. He pointed out that G.O.Ms.No.64 dated 19.2