JUDGMENT : N.V. ANJARIA, J. In all the captioned Special Civil Applications, the facts are similar and the issues identical. As the petitions are cognate and in group, were notified and heard together. They are being considered and disposed of simultaneously by this common judgment. 2. The common petitioner has challenged different orders–all dated 29.07.2010 in each of the petitions passed by Chief Controlling Revenue Authority- respondent No.1 herein whereby the said authority cancelled order 24.12.2004 of the Deputy Collector– respondent No.2 herein. As a consequence, the certificates issued by respondent No.2 under Section 32A of the Bombay Stamp Act, 1958 (now, Gujarat Stamp Act, 1958) in respect of the instruments of deed of conveyance were set at naught and in each case, the market value of the land came to be assessed requiring the petitioner concerned to pay the additional stamp duty and penalty. 3. Stating the relevant facts, the petitioner–Mit Housing Association in each case, purchased different land properties in an auction sale from respondent No.4–Gujarat State Textile Corporation Limited. As far as first Special Civil Application No. 1008 of 2011 is concerned, the property purchased was plot No.27 admeasuring 300 sq. mtrs. of land revenue survey No.609 paiki at Vadodara. The sale was confirmed in favour of the petitioner as he was the highest bidder. Sale deed bearing No. 5583 dated 01.11.1996 (new No. 221 dated 17.01.1997) came to be executed. 3.1 At that time, upon presentation of the sale deed for registration, respondent No.2 took a view that no procedure under Section 32A was required to be undertaken and since the purchase of the land was from respondent No.4 corporation, stamp duty was exempted. Certificates of exemption under Section 32A came to be issued by respondent No.2 on 24.12.2004. Subsequently, respondent No.1 exercised powers under Section 53A of the Bombay Stamp Act, 1958 and cancelled the certificate of exemption, determining the market value of the property to the tune of Rs.15,99,900/- and directing recovery of additional stamp duty of Rs.1,92,276/- together with penalty of Rs.250/- from the petitioner. 3.2 The Certificates of exemption and the date of impugned order are same in all cases. The market value determined in each case was Rs.15,99,900/- and recovery of additional stamp duty directed was Rs.1,92,276/- plus penalty of Rs.250/- in each case. 3.2 The Certificates of exemption and the date of impugned order are same in all cases. The market value determined in each case was Rs.15,99,900/- and recovery of additional stamp duty directed was Rs.1,92,276/- plus penalty of Rs.250/- in each case. 3.3 For the purpose of completion of recording of facts, the minimum details about sale deed and plot numbers in each case, are stated in the tabular form hereinbelow, Sr. No. Special Civil Application No. Sale Deed Number & Date Description of the property (of Revenue Survey No. 609 of Vadodara 1 SCA No. 1008 OF 2011 No.5583 dated 01.11.1996 (new No. 221 dated 17.01.1997) Plot No.27, admeasuring 300 sq. mtrs. 2 SCA No. 1009 of 2011 No.5584 dated 01.11.1996 (new No. 222 dated 17.01.1997) Plot No.20, admeasuring 300 sq. mtrs. 3 SCA No. 1010 of 2011 No.5585 dated 01.11.1996 (new No. 223 dated 17.01.1997) Plot No. 19, admeasuring 300 sq. mtrs. 4 SCA No. 1011 of 2011 No.5586 dated 01.11.1996 (new No. 224 dated 17.01.1997) Plot No. 18, admeasuring 300 sq. mtrs. 5 SCA No. 1012 of 2011 No.5587 dated 01.11.1996 (new No. 225 dated 17.01.1997) Plot No. 23, admeasuring 300 sq. mtrs. 6 SCA No. 1013 of 2011 No.5588 dated 01.11.1996 (new No. 226 dated 17.01.1997) Plot No. 24, admeasuring 449.37 sq. mtrs. 7 SCA No. 1014 of 2011 No.5589 dated 01.11.1996 (new No. 227 dated 17.01.1997) Plot No. 25, admeasuring 449.37 sq. mtrs. 8 SCA No. 1015 of 2011 No.5590 dated 01.11.1996 (new No. 228 dated 17.01.1997) Plot No. 16, admeasuring 300 sq. mtrs. 9 SCA No. 1016 of 2011 No.5591 dated 01.11.1996 (new No. 229 dated 17.01.1997) Plot No. 21, admeasuring 300 sq. mtrs. 10 SCA No. 2017 of 2011 No.5592 dated 01.11.1996 (new No. 230 dated 17.01.1997) Plot No. 33, admeasuring 300 sq. mtrs. 11 SCA No. 1018 of 2011 No.5593 dated 01.11.1996 (new No. 231 dated 17.01.1997) Plot No. 31, admeasuring 300 sq. mtrs. 12 SCA No. 1019 of 2011 No.5594 dated 01.11.1996 (new No. 232 dated 17.01.1997) Plot No. 29, admeasuringsq. mtrs. 300 13 SCA No. 1020 of 2011 No.5595 dated 01.11.1996 (new No. 233 dated 17.01.1997) Plot No. 26, admeasuringsq. mtrs. 300 14 SCA No. 1021 of 2011 No.5596 dated 01.11.1996 (new No. 234 dated 17.01.1997) Plot No. 22, admeasuringsq. mtrs. 300 15 SCA No. 1022 of 2011 No.5597 dated 01.11.1996 (new No. 235 dated 17.01.1997) Plot No. 28, admeasuringsq. mtrs. 300 13 SCA No. 1020 of 2011 No.5595 dated 01.11.1996 (new No. 233 dated 17.01.1997) Plot No. 26, admeasuringsq. mtrs. 300 14 SCA No. 1021 of 2011 No.5596 dated 01.11.1996 (new No. 234 dated 17.01.1997) Plot No. 22, admeasuringsq. mtrs. 300 15 SCA No. 1022 of 2011 No.5597 dated 01.11.1996 (new No. 235 dated 17.01.1997) Plot No. 28, admeasuringsq. mtrs. 300 3.4 It appears that total 15 documents dated 01.11.1996 bearing Nos. 221 to 235 were executed. The certificate under Section 32A was given exempting payment of stamp duty on the footing that Gujarat State Textile Corporation Limited was a government corporation, and under the Proviso to Section 32A, the conveyance of property would entitle for the exemption. Accordingly the Collector certified under Section 32A on 24.12.2004 read with the Resolution dated 30.09.1991 of the Revenue Department that it was exempt under Section 32A. It appears that thereafter, the petitioner approached respondent No.2 requesting to hand over copy of the sale deeds. He subsequently issued notice to the authority through advocate asking for the sale deed duly registered and returned. 3.5 The Deputy Collector appears to have addressed letter dated 06.12.2008 to the Superintendent of Stamp stating that the cases were required to be taken in revision for the various reasons including for considering whether the transaction by Gujarat State Textile Corporation Limited could qualify for exemption under Section 32A of the Act. It was thereafter that the proceedings were initiated by the Chief Controlling Revenue Authority by issuing notice dated 17.05.2010 in each case. In the said notice, the details were indicated and the petitioner was called upon to show cause. After complying with the principle of natural justice, the impugned order came to be passed. 4. Two principal contentions were vehemently raised to assail the impugned orders by learned advocate Mr. N.K. Majmudar appearing with learned advocate Mr. Shaker Jadeja appearing for the petitioner. First was that the exercise of powers by respondent No.1 under Section 53A was much delayed exercise, hence liable to be set aside. It was submitted that the sale deed was of the year 1996-1997, the exemption certificates were dated 24.12.2004 and after about six years, the Chief Controlling Authority exercised the powers. For the reason of inordinate delay, the impugned orders were rendered bad in law, it was submitted. It was submitted that the sale deed was of the year 1996-1997, the exemption certificates were dated 24.12.2004 and after about six years, the Chief Controlling Authority exercised the powers. For the reason of inordinate delay, the impugned orders were rendered bad in law, it was submitted. It was secondly submitted that as the purchase of the property was from Gujarat State Textile Corporation Limited which was a government corporation, the exemption was rightly granted by the Deputy Collector under Section 32A of the Act read with aforementioned Resolution of the Revenue Department. 5. The relevant provisions may be considered. Section 53A of the Act under which the powers are exercised by respondent No.1-the Chief Controlling Authority reads as under, “53A. Revision of Collector’s decision under sections 32, 32A, 39 and 41 (1) Notwithstanding anything contained in sub-section (3) of section 32, sub-section (3) of section 32A, sub-section (2) of section 39 and sub-section (2) of section 41, when through mistake or otherwise any instruments is charged with less duty than leviable thereon, or is held not chargeable with duty, by the Collector, the Chief Controlling Revenue Authority may, within a period of six years from the date of certificate of the Collector under sections 32, 32A, 39 or 41, as the case may be, required the concerned party to produce before him the instrument and, after giving reasonable opportunity of being heard to the party, examine such instrument whether any duty is chargeable or any duty is levied less thereon and pass an order for recovery of the deficit duty, if any, from the concerned party. An endorsement shall be made on the instrument after payment of such deficit duty. (2) On failure to produce the original instrument by the party, the Chief Controlling Revenue Authority shall proceed under this section on the basis of the true copy or an abstract of the instrument filed with the Collector and such true copy or abstract shall be deemed to be the original instrument for the purposes of this section.” 5.1 The aforesaid provision in Section 53A gives power of revision to the Chief Controlling Revenue Authority over the Collector’s decision taken under Sections 32, 32A, 39 or 42 of the Act. In the present case, certificate of exemption was issued under Section 32A of the Act. In the present case, certificate of exemption was issued under Section 32A of the Act. 5.2 Section 32A is extracted hereunder, “32A: Determination of market value of property which is the subject matter of conveyance, etc. (1) Every instrument of conveyance, exchange, gift, certificate of sale, partition partnership, settlement, power of attorney to sell immovable property when given for consideration or transfer of lease by way of assignment, presented for registration under provisions of the Registration Act, 1908 (XVI of 1908) shall be accompanied by a true copy thereof; and the Statement in such form as may be prescribed by rules and if an officer registering such instrument under the aforesaid Act or any person referred to in section 33 before whom such instrument is produced or comes in the performance of his functions, has reason to believe that the consideration set forth therein does not approximate to the market value of the property which is the subject matter of such instrument or as the case may be the market value of the property which is the subject matter of such instrument, has not been truely set forth therein, he shall before registering the instrument or, as the case may be, performing his functions in respect of such instrument, refer the instrument or true copy thereof to the Collector of such district in which either the whole or any part of the property is situated for determining the true market value of such property and the proper duty payable on the instrument under this section. Provided that for the purpose of this Sub-section, the consideration set forth in an instrument executed by the State Government, the Central Government, a local authority, Gujarat Housing Board, Gujarat Slum Clearance Board or Gujarat Industrial Development Corporation, shall be deemed to be the true market value of the property which is the subject matter of such instrument. (2) ............ (3) ............ (4) ............” 5.3 The Proviso to sub section (1) of Section 32A says that as far as an instrument executed by the State Government, Central Government, local authority, Housing Board, Gujarat Slum Clearance Board and the Gujarat Industrial Development Corporation is concerned, whatever consideration is set forth in the instrument executed by the said named government or authority or Board or Corporation, shall be deemed to be the true market value of the property. 6. 6. Adverting to contentions of the petitioner, first was that respondent No.1 exercised powers under Section 53A belatedly. It was pressed by learned advocate for the petitioners that the sale deeds were of the year 1996, whereas the powers under Section 53A were exercised after several years and that the said powers were invoked as late as in the year 2010. It was submitted that even if counted from the date of certificate under Section 32A, that is, 24.12.2004, time of almost six years elapsed resulting into unreasonable delay. 6.1 Section 53A contemplates a period of six years for the Chief Controlling Revenue Authority to exercise his powers from the date of the certificate given under Section 32A. As noted above, in the present cases, the Deputy Collector made certificate under Section 32A on 24.12.2004. Respondent No.1 Chief Controlling Revenue Authority invoked his powers and issued notice 17.05.2010 under Section 53A and finally passed the impugned order dated 29.07.2010. Therefore, reckoned either from the date of the order or even from the date of the notice under Section 53A the powers are exercised within six years. When Section 53A contemplates a period of six years for the authority to act and exercise powers conferred to it thereunder, and the authority has acted during the said period, the ground of delay would not be available to assail the exercise of powers; it was within the time-limit even though invocation may, no matter be at the fag-end. 6.2 When a statute prescribes a specified period either by way of limitation or outer limit for discharging a particular function by the authority or taking any action or passing some order, or for any such other purpose, entire period is available to the authority on whom such power is conferred, to invoke his powers and exercise the same. The authority may exercise powers even at the end of such period. But in such eventuality, it cannot be said that the authority acted on the verge of expiry of the period permitted under the statute and thus whiled away the time. The action taken or order passed by the authority concerned acting within the time period would not be prone to be assailed on the ground that there was delay in exercising the powers, so long as the exercise falls within the stipulated time period. The action taken or order passed by the authority concerned acting within the time period would not be prone to be assailed on the ground that there was delay in exercising the powers, so long as the exercise falls within the stipulated time period. 6.3 Taking this position to the impugned action, it is an admitted position that respondent No.1-Chief Controlling Revenue Authority acted and exercised his powers within a period of six years from the date of the certificate of the Deputy Collector under Section 32A. Suo motu powers available to the Chief Controlling Revenue Authority was exercised by issuing notice and passing order within six years contemplated under Section 53A, ruling that certificate of the Deputy Collector exempting stamp duty was not acceptable as the Gujarat State Textile Corporation was not falling within the umbrella of the proviso so as to qualify for stamp duty exemption. Once the Chief Controlling Revenue Authority has exercised his powers within a period of six years from the date of certificate of the Deputy Collector, the plea that the authority acted after unreasonable long time can in no way be countenanced. The concept of unreasonable delay for exercise of powers does not arise in this case for the reason already stated that it is the statutory provision itself which prescribed the period of six years and within which the authority concerned has acted. 6.4 The second limb of the submission that Gujarat State Textile Corporation was a government corporation, therefore conveyance by it was exempted from stamp duty under the proviso to Section 32A is equally meritless. The proviso to Section mentions specific categories in respect of which the stamp duty is exempted and certificate under Section 32A for exemption could be issued. The categories mentioned are the State Government, Central Government, local body; it thereafter names particular boards and corporations to be Gujarat Housing Board, Gujarat Slum Clearance Board or Gujarat Industrial Development Corporation. The Gujarat State Textile Corporation does not fall in any of the category of State Government, Central Government, nor it is a local body. It is not a board or corporation specifically named. It is a statutory corporation, however separate entity and it cannot be equated with the State Government or Central Government to be included for the purpose of proviso to the Section. It is not a board or corporation specifically named. It is a statutory corporation, however separate entity and it cannot be equated with the State Government or Central Government to be included for the purpose of proviso to the Section. It is settled that even if a body can be said to be instrumentality of the State for the purpose of ambit of Article 12, such body or instrumentality cannot be for the said reason becomes State Government or could be placed on the same pedestal of the State Government. Therefore Gujarat State Textile corporation is a legal entity duly constituted and has separate existence not to be equated or included within the concept of the State Government or Central Government. Certain boards and corporations which the Legislature wanted to be the beneficiaries are specifically named in the proviso. Gujarat State Textile Corporation is not mentioned nor stands included. 6.5 Resolution dated 30.09.1991 is based on the aforesaid provision, that is proviso to Section 32A, mentioning categories as above. Therefore the decision of the Deputy Collector to give exemption certificate under Section 32A of the Act on the ground that the property belonged to Gujarat State Textile Corporation was erroneous and the exemption certificate was not permissible in law. The conveyance of the property by the said Gujarat State Textile Corporation does not qualify for exemption from stamp duty. Decision of the Collector and the certificate of exemption dated 24.12.2004 was therefore bad on merits as well. The said decision is rightly set-at-naught by the Chief Controlling Revenue Authority by exercising powers in accordance with Section 53A of the Act. 7. In view of the above reasons and discussion, none of the contentions raised to assail the impugned decision could be accepted. The impugned orders are just, proper and legal. No interference is warranted therein on any ground. All the petitions are hereby dismissed. Notice in each petition stands discharged.