The petitioner calls in question the order dated 17.11.2015 passed by the first respondent, confirming the order dated 04.06.2015 of the second respondent. By the said order dated 17.11.2015, the first respondent rejected the statutory revision preferred by the petitioner and directed her to pay the deficit stamp duty of Rs. 5,34,788/- together with penalty of Rs. 1,212/- as has been assessed by the second respondent in respect of the lease deed dated 06.04.2015.

2. The facts which led to the institution of the aforesaid writ petition can be briefly stated as follows:-

(i) A large tract of land measuring 1550 acres was owned by M/s. Mahindra World City Developers Limited. The said owner in turn has executed perpetual lease in favour of the fourth respondent in respect of the land measuring 218.982 acres from and out of the 1550 acres owned by them by means of various registered sale deeds for the purpose of development of residential facilities. The fourth respondent is a duly approved Small Economic Zone Co-developer which was recognised by the Board of Approval, Ministry of Commerce and Industry, Government of India by a letter of approval dated 24.08.2008 whereby the fourth respondent was authorised to develop residential facilities in the non-processing area of Small Economic Zone (hereinafter referred to as 'SEZ'). On the basis of such approval, the fourth respondent prepared a scheme to develop the above said lands by constructing residential units such as Villas, Town Homes and Apartments. In the course of such development, the petitioner herein has entered into a lease with the fourth respondent for taking out a residential unit with an intention to let it out to the employees of the SEZ. Accordingly, a lease deed dated 06.04.2015 was executed in favour of the petitioner by the fourth respondent on a non-judicial Stamp paper of Rs.20/-. According to the petitioner, such lease deed executed in her favour by the fourth respondent is exempted from payment of stamp duty as per Rule 11 (10) of the SEZ Rules and Section 3 of the Indian Stamp Act and therefore, the petitioner need not pay any stamp duty on the instrument viz., Lease Deed.

(ii) When the petitioner presented the lease deed dated 06.04.2015 for registration with the third respondent, the third respondent examined the same and referred it to the second respondent with his remarks. The second respondent, after examining the lease deed, has issued a show cause notice dated 03.07.2015 to the petitioner calling upon her to explain as to why an order be not passed for collection of stamp duty of Rs. 5,34,788/- with penalty of Rs. 1,212/- from her. The petitioner submitted a reply dated 15.07.2015 contending that the lease deed is in respect of a non-processing unit of SEZ and it was executed by the fourth respondent, a Co-developer of SEZ. Further, the lease deed has been executed to carry out the purposes which have been spelt out in the SEZ Rules. It was further replied that the Co-developer can lease out the residential unit in favour of any person in respect of the land or building situate within the non-processing area and there is no embargo or restriction for the same in the SEZ Act or Rules. In such circumstances, the instrument presented for registration, in respect of a non-processing area within the SEZ, is exempted from payment of stamp duty. Notwithstanding such reply, the second respondent, by the order dated 04.08.2015, concluded that the lease deed presented by the petitioner is not exempted from payment of stamp duty. According to the second respondent, the exemption of stamp duty provided in Section 3 of the Indian Stamp Act, 1899 cannot be extended to the lease deed presented by the petitioner. Therefore, the second respondent justified the demand for payment of deficit stamp duty and penalty made by the third respondent. Aggrieved by the same, the petitioner has filed a revision before the first respondent.

(iii) The first respondent/revisiona