Mutation on registered sale deed cannot be refused, and company tax dues cannot be charged against purchasers' personal property.

Registered sale deeds must be reflected in revenue records, as mutation is a fiscal entry and not a forum for deciding title or refusing certification on matters reserved for other statutes. A revenue authority cannot decline mutation of a registered transfer by entering questions outside its limited jurisdiction. A charge also cannot be fastened on purchasers' personal properties for a company's tax dues absent express statutory authority, especially where the properties were transferred by registered deed before the charge was sought. If fraudulent transfer is alleged, the proper remedy lies before the civil court. The mutation rejection and consequential entries were therefore unsustainable.

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Issues: (i) Whether the revenue authorities were bound to mutate the names of purchasers on production of a registered sale deed under the land revenue law. (ii) Whether a charge could be entered over the purchasers' personal properties on account of the vendor-director's company tax dues under the value added tax law. (iii) Whether the impugned communications and mutation entries were liable to be set aside and the purchasers' mutation application allowed.

Issue (i): Whether the revenue authorities were bound to mutate the names of purchasers on production of a registered sale deed under the land revenue law.

Analysis: A registered conveyance of immovable property confers a right requiring reflection in the revenue record. Revenue entries are maintained for fiscal purposes and do not adjudicate title, but the authority cannot refuse mutation of a registered transfer by entering upon questions belonging to another enactment. The limited jurisdiction under the land revenue code requires certification of the entry on the basis of the registered document, leaving disputes under other statutes to the competent forum.

Conclusion: This issue was decided in favour of the petitioner.

Issue (ii): Whether a charge could be entered over the purchasers' personal properties on account of the vendor-director's company tax dues under the value added tax law.

Analysis: The tax dues belonged to the company, while the properties in question were found to be the personal properties of the director and had already been transferred by registered sale deed before the charge was sought to be created. The statutory power relied upon could not be used to fasten the company's liability on the personal properties of a director absent a specific statutory foundation. If the department asserted that the transfer was intended to defraud revenue, the proper course was to pursue proceedings in the civil court rather than create a charge administratively against third-party purchasers.

Conclusion: This issue was decided in favour of the petitioner.

Issue (iii): Whether the impugned communications and mutation entries were liable to be set aside and the purchasers' mutation application allowed.

Analysis: Since the charge was not sustainable and the purchasers were bona fide transferees under a registered sale deed, the rejection of their mutation request could not stand. The impugned communications and entries were consequential to an ultra vires attempt to burden the property with company tax dues and were therefore unsustainable.

Conclusion: This issue was decided in favour of the petitioner.

Final Conclusion: The proceedings could not lawfully burden the petitioners' acquired properties with the erstwhile company's tax dues, and the registered transfer had to be reflected in the revenue records.

Ratio Decidendi: A revenue authority exercising mutation powers cannot refuse certification of a registered sale deed or create a charge on a purchaser's property for a company's tax dues unless the statute expressly authorises such action; if fraudulent transfer is alleged, the remedy lies in proceedings before the competent civil court.

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