The petitioner, a Tenant Co-Partnership Housing Society Limited established under the Maharashtra Co-operative Societies Act, 1960, sought deemed conveyance for flats in its possession. The Competent Authority had initially granted this request on February 11, 2014, directing the society to fulfill specific registration formalities. This included consulting the Collector of Stamps to determine the appropriate stamp duty for the deemed conveyance deed.

On September 28, 2015, the Collector issued an interim order assessing deficit stamp duties for Flat No. 218 and Flat No. 320, totaling amounts of Rs. 25,150 and Rs. 1,90,040, respectively. This interim decision was subsequently finalized in an order dated May 2, 2016. Following this, the society's appeal against the interim order was dismissed by the appellate authority, which asserted that the issue was outside the scope of the applicable stamp law.

Counsel for the petitioner argued that the demands imposed by the authorities would hinder the society's ability to secure deemed conveyance. Notably, while the petitioner conceded that the amount for Flat No. 218 had already been paid, he contested the demand for Flat No. 320. He referenced an earlier payment of Rs. 7,060 made in 1995 under an Amnesty Scheme and emphasized that any further demands were barred by the six-year limitation stipulated in Section 53A of the Bombay Stamp Act.

On the other hand, the government representative justified the demands, contending that the original agreement from 1989 was unregistered and therefore subject to current valuation standards. This, they argued, justified the calculation of a deficit stamp duty based on contemporary market values.

The primary issue before the court was the legality of the stamp duty demand for Flat No. 320. The court noted that the 1995 payment, accompanied by a certificate confirming the duty was fully paid, was subject to Section 53A, which allows for a six-year period to contest any errors regarding stamp duty. Given that the certificate was issued on March 2, 1995, and the demands were made well after this six-year period, the court deemed the demands for Flat No. 320 invalid.

The court further clarified that the reliance on the recent amendments to the Maharashtra Stamp Act did not apply in this case. The provisions cited by the respondents were misaligned with the facts, as they pertained to registered agreements and not the unregistered nature of the original document.

The court ruled in favor of the petitioner, quashing the orders dated May 2, 2016, and July 16, 2016, that imposed the stamp duty demands. The court ordered the refund of the amounts deposited by the petitioner, emphasizing the necessity for a reasonable timeframe in raising such demands, especially after a significant lapse of time.

This case highlights the critical intersection of property rights and tax obligations, particularly the importance of adhering to statutory time limits in administrative proceedings. The ruling not only reinforces the rights of housing societies but also serves as a precedent regarding the limitations on demanding retrospective duties.