( 1 ) THE writ petitioner has filed the present appeal assailing the order of the learned single Judge dated 5-2-1999 in W. P. No. 18950/92 dismissing the writ petition. ( 2 ) THE brief facts of the case are :the KIADB, at the instance of the appellant company acquired certain lands and the lands were handed over to the appellant company under an agreement of lease. After the expiry of the lease period, the KIADB, executed two sale deeds and these sale deeds were sent to the appellant company to get them registered before the jurisdictional Registrar. When presented for Registration before respondent No. 4, he insisted that stamp duty will have to be paid in respect of the said deeds. The appellant-company submitted a representation to the District Registrar, Respondent No. 3, stating that there is exemption provided from payment of stamp duty in view of Sec. 43 of the Karnataka Industrial Areas Development Board Act, 1966 (hereinafter referred to as 'the Act' ). But the District Registrar and the Sub-Registrar turned down the representation and the appellant paid the stamp duty under protest to get the deeds registered. After registration, the appellant took up the matter again with the Karnataka Industrial Areas Development Board and the respondents by making several representations but to no avail. Hence, the appellant filed the writ petition. The learned single Judge dismissed the writ petition. ( 3 ) ASSAILING the order of the learned single Judge, the appellant has filed the present appeal contending inter alia, that no stamp duty is payable on the sale deeds executed by the KIADB in favour of the appellant and the same is exempted in view of Sec. 43 of the Act which provides for exemption from payment of stamp duty and the registration fee in respect of documents executed by KIADB. ( 4 ) WE have heard the learned counsel for both parties. ( 5 ) THEREFORE, the question that arises for our consideration is :whether a sale effected by the Board is exempt from payment of stamp duty and fee under the Mysore Stamp Act or under the Indian Registration Act ? ( 6 ) IN order to decide the question that is involved in the appeal, it is necessary to extract the relevant provisions of the KIADB Act. ( 6 ) IN order to decide the question that is involved in the appeal, it is necessary to extract the relevant provisions of the KIADB Act. The documents in question are executed by the KIADB under Sec. 14 (a) of the Act. Sec. 14 (a) of the Act reads as follows :"14. General powers of the Board 1. Subject to the provisions of this Act, the Board shall have the power, (a) to acquire and hold such property, both movable and immovable as the Board may deem necessary for the performance of any of its activities and to lease, sell, exchange or otherwise transfer any property held by it on such conditions as may be deemed proper by the Board;"in Clause (a) of Sec. 14 the words used are '. . . to lease, sell, exchange or otherwise transfer any property held by it on such otherwise transfer any property held by it on such conditions as may be deemed proper by the Board;' Sub-sec. (h) of Sec. 14 of the Act states, 'to enter into and perform all such contracts as it may consider necessary or expedient for carrying out any of its functions;' ( 7 ) SEC. 43 deals with the exemption of stamp duty and fees and it reads :"no award or agreement or contract made or executed under this Act or under any rule or Regulation made thereunder shall be chargeable with duty under the Mysore Stamp Act, 1957 or under the Indian Registration Act, 1908. " ( 8 ) UNDER the Act the words 'award' 'agreement' or 'contract' are not defined; whereas under the Karnataka Stamp Act 1957, Sec. 2 (d) defines 'conveyance' which includes a conveyance of sale and every instrument by which property, whether moveable or immoveable, is transferred. ( 9 ) THE learned counsel for the appellant has submitted that there is no difference between the word 'contract' and 'conveyance', since conveyance is nothing but a 'contract of sale'. Therefore, it is contended by him that such an instrument is exempt from duty and fees under the respective provisions referred to supra. ( 10 ) THE point whether the words 'contract' as found in Sec. 43 of the Act would mean and include conveyance also, came up for consideration before the learned single Judge of this Court in M/s. Pals Industries Limited v. The District Registrar, ILR 1999 Kant 322. ( 10 ) THE point whether the words 'contract' as found in Sec. 43 of the Act would mean and include conveyance also, came up for consideration before the learned single Judge of this Court in M/s. Pals Industries Limited v. The District Registrar, ILR 1999 Kant 322. The learned single Judge, while discussing the question drew a distinction between 'contract' and 'sale' in the following terms :"the term 'contract' is not defined under the Act. A contract is a legally binding agreement between two or more persons which creates an obligation to do or not to do a particular thing. A contract in so far as Sales are concerned, for purposes of Stamp Laws, is a contract to sell or a contract for sale, which is an executory contract. A sale, which is an executed contract, is a conveyance and is not called a 'contract'. "thus, the learned single Judge has drawn a clear distinction between a 'contract of sale' and a 'conveyance'. ( 11 ) WE find that the distinction so made by the learned single Judge is supported by good reasoning. Though, for purposes of General Law, it can said that conveyance is nothing but a contract of sale as it has all the trappings of a contract, for the purposes of the Act it must be said that the contract would cease to be a contract as defined in Sec. 43 the moment the process of conveyance begins. It has to be emphasised that the intention of the Legislature in framing S. 43 of the Act appears to be, to save the KIADB the bother of paying the stamp-fee for all agreements or contracts entered into by it with third parties, where the beneficiary of such an agreement or contract would be the Board itself. The moment the Board divests itself of all the right, title or interest in a certain property to bestow it on a third party, then the said transaction loses the character of a contract as defined in S. 43 of the Act and becomes a pure and simple sale or conveyance on which stamp-fee is to be paid by the beneficiary concerned and the exemption that is available under S. 43 would no longer survive for the benefit of the third party. Surely, S. 43 of the Act cannot be interpreted to mean that the benefit of exemption provided therein is to be extended to the beneficiary of a total 'sale' when all the right, title and interest in the property is being divested in favour of the beneficiary by the Board. While it is true that statutes should be interpreted to mean what could be gathered from the language in which the provisions are coined, where a simple interpretation would lead to preposterous results, it necessitates going beyond the meaning that could be gathered from a simple reading of the provision to find out what could have been the intention of the Legislature when it framed a particular statute. Sec. 43 necessitates such an exercise as otherwise it would lead to absurd results. Thus, interpreted, it is clear that S. 43 of the Act would not include any sale or conveyance made by the Board in favour of a beneficiary. So it boils down to the fact that in the ultimate analysis the test to be adopted in finding out whether or not an agreement, award or contract made by the Board is liable to stamp duty and fees or not is to see who the beneficiary is. Tested as such the beneficiary in the present case being the appellant industry it goes without saying that it is bound to pay the stamp duty and fee under the Stamp Fees Act. ( 12 ) THE above interpretation also gains support from the wordings in which the provision is coined. At the cost of repetition we extract Sec. 43 of the Act which reads :"no award or agreement or contract made or executed under this Act or under any rule or Regulation made thereunder shall be chargeable with duty under the Mysore Stamp Act, 1957 or under the Indian Registration Act, 1908. "the section though employs the words 'no award or agreement or contract made or executed' stops at that and does not proceed to state whether executed by the Board in favour of a third party or by a third party in favour of the Board. If it were to be the intention of the Legislature to provide the benefit accruing under S. 43 of the Act to a third party contracting with the Board then surely the words 'executed by the Board' would have been inserted in the section. If it were to be the intention of the Legislature to provide the benefit accruing under S. 43 of the Act to a third party contracting with the Board then surely the words 'executed by the Board' would have been inserted in the section. While it can be said that the section is not happily worded, it cannot be gainfully said that every contract or agreement in pursuance of which a benefits is bestowed by the Board on a third party is exempt from stamp-fee or duty. ( 13 ) IN the view that we have taken in the matter, we find that the provisions of Karnataka Stamp Act, 1957 and the Indian Registration Act, 1908 do apply to a conveyance effected by the Board in favour of a third party and the stamp fee or duty becomes liable to be paid. ( 14 ) HENCE, we find no merit in the appeal and it is, accordingly, dismissed. --- *** --- .