divided into three parts. A portion admeasuring 1036 sq. yards together with buildings and structures standing thereon was alloted to Jhaverchand Kheraj and 4 others. These four others included Jhaverchand's mother, wife and two children. Another portion admeasuring 259 sq. yards together with buildings and structures thereon, was allotted to a group of other owners (forming part of 20 owners). This portion of 259 sq. yards was eventually transferred to Jhaverchand Kheraj and others, holders of the portion admeasuring 1036 sq. yards, in or about 1969. Jhaverchand Kheraj and 4 others, thus, came to own 1295 sq. yards of the larger property, which is the suit property. By a Will executed by the mother of Jhaverchand Kheraj, her 40% share in the suit property devolved upon three trusts, one for the benefit of Jhaverchand himself and two for the benefit of his sons, Ketan and Kiran. As a result of the failure of the object of the trust, the trust created in favour of Ketan was dissolved on 17 April 2005 and in its place an association of persons came to be formed. That association of persons, which included Jhaverchand, his wife and his two sons both individually and as trustees, owned the interest held earlier in the suit property by the dissolved trust. After Amratbai, wife of Jhaverchand expired, her share devolved upon Jhaverchand and his two sons as legal heirs of the deceased Amratbai. That is how the present owners of the suit property, namely, Jhaverchand and his two sons in their respective individual capacity and as association of persons and trustees of the two trusts referred to above came to own the suit property. That is how they executed the conveyance transferring their title in favour of the first petitioner society. The conveyance indicates that about 17 units in the building existing on the suit property have been retained by the owners. The dispute in the present matter concerns the incidence of stamp duty, if any, payable on these 17 units. As a matter of law, it is not disputed that if
