1. This appeal is filed against the Proceedings of the 1st respondent dated 24.06.2011 in g/K/vz;.14918/N2/2008, whereby the order passed by the 2nd respondent in rp/g/vz;/ 95/03/TGE dated 19.11.2007, directing the appellant to pay a sum of Rs.10,52,606/- as deficit stamp duty, was confirmed.

2. The facts, which are necessary to decide the issue involved in the appeal, are as follows:

(a) One M/s.Sankar Paper and Board Mills Private Limited had borrowed a loan from the State Industries Promotion Corporation of Tamilnadu Limited (SIPCOT), by creating an equitable mortgage by deposit of title deeds on 18.03.1994 in respect of a property situated in S.No.135/1A measuring 4.20 acres, S.No.263/1A measuring 3.00 acres and S.No.264/1 measuring 2.95 acres with buildings, other structures, fixtures, fittings and machineries thereon in A.Erayamangalam Village. Subsequently, the said Sankar Paper and Board Mills Private Limited committed a default in payment of the loan amount and the SIPCOT, by resorting to Section 29 of the State Financial Corporation Act, 1951, took possession of the mortgaged assets on 16.07.1998 and called for tenders in public auction through advertisements/lim