( 1 ) PETITIONER a registered company incorporated and registered under the Companies Act, 1956 having its factory at Malanpur Industrial area, District Bhind, M. P. , has called in question tenability of order the dated 7-11-2001 (Annexure-Q) passed by the Collector of Stamps, bhind directing for payment of stamp duty and penalty on a document, executed in connection with transfer of certain property conveyed by the deed (Annexure-F) dated 13th June, 1996 so also the order passed by the Board of Revenue, the Chief Controlling Revenue Authority under the Indian Stamp Act, 1899 (Annexure-T) dated 3-1-2002 and the consequential demand notices Annexure-R and Annexure-S dated 12-11-2001 and 22-12-2001 demanding stamp duty of Rs. 23,72,50,000/- and a penalty of Rs. 5,09,05,000/ -.

( 2 ) IT is the case of the petitioner that originally their unit at Malanpur (M. P.) known as Tyre Cord Manufacturing Unit was owned by the 4th respondent M/s. Ceat Ltd. , who were owners of the undertaking which included the leasehold land, building, immovable plant and machinery and other movable and immovable assets including rights and obligations of the business.

( 3 ) THAT, on 24-3-19