JUDGMENT Manish Pitale, J. - The Petitioner is aggrieved by two notices issued by the Respondent-Goa Industrial Development Corporation. One pertains to demand in respect of differential transfer fees amounting to Rs. 26,61,61,500/-. The other notice pertains to arrears of annual rent allegedly payable by the Petitioner to the Respondent-Corporation. The demand towards the differential transfer fees and arrears of annual rent pertained to a plot admeasuring 2,41,965 square metres situated at Sancoale, Mormugao Taluka, South Goa. The said plot was acquired by the Government of Goa for the Respondent-Corporation under a pre-acquisition agreement with M/s. Meta Copper & Alloys Ltd. (formerly known as Meta Strips Ltd.). The said plot was leased to the said M/s. Meta Copper & Alloys Ltd., under a Deed of Lease dated 24.12.1998, for a period of 30 years with annual lease rent fixed at Rs. 73,567/-. 2. The aforesaid M/s. Meta Copper & Alloys Ltd. developed the entire plot as it was a barren piece of land when possession was handed over and, sometime in the year 2001, it commenced manufacturing activity on the said plot of land. The manufacturing activity continued till the year 2011. 3. At this stage, an exercise was undertaken for transfer of the said lease in favour of the Petitioner. The Petitioner applied for such transfer before the Respondent-Corporation on 11.03.2015, for setting up a Logistic and Warehousing Hub to cater to the needs of existing Industry and Port in the State. Initially, the Corporation stated that transfer of such plot of land was beyond Transfer and Sub-lease Regulations of the Corporation framed in the year 2014 and, on this basis, it was stated that the Corporation was unable to take a decision in the matter. In this situation, the Petitioner approached the Government of Goa, and eventually on 23.12.2016, the Government granted approval to such transfer of the lease. The Petitioner was asked to submit requisite documents for processing the transfer of the lease. The Petitioner made a representation to the Respondent-Corporation for considering grant of special rates instead of standard rates for developed plots of Rs.2,200/- per square metre. It was claimed that a huge cost was incurred for carrying out development in the plot and that this factor ought to have been taken into consideration while fixing the annual lease rent. 4. The Petitioner made a representation to the Respondent-Corporation for considering grant of special rates instead of standard rates for developed plots of Rs.2,200/- per square metre. It was claimed that a huge cost was incurred for carrying out development in the plot and that this factor ought to have been taken into consideration while fixing the annual lease rent. 4. As there was a change in the constitution of the Petitioner-company, the Respondent-Corporation requested for an updated application, which was submitted on 10.02.2017. On this basis, the Respondent-Corporation asked the Petitioner to deposit an amount of Rs.6,35,59,048/- for issuance of transfer order pertaining to the Lease Deed. On 10.03.2017, the Petitioner transferred the said amount through RTGS into the account of the said Respondent-Corporation. Accordingly, on 10.03.2017, the Respondent-Corporation issued an order for transfer of the Lease Deed. In pursuance thereof, on 24.03.2017, a Tripartite Deed of Lease was executed between the Petitioner, the Respondent-Corporation, and the aforesaid M/s. Meta Copper and Alloys Ltd. as a confirming party. 5. On 10.07.2017, the Respondent-Corporation issued a letter to the Petitioner demanding payment of additional transfer fee for the transfer of the lease, on the ground that there had been a mistake in charging the transfer fee at the rate of 10% instead of 60%. It was claimed that since the definition of the expression "substantial construction" was changed as per Notification dated 22.12.2016, whereby the Goa-IDC Transfer and Sub-Lease Regulations, 2014, stood amended, the rate of 60% was applicable on the transfer fee, as on the date on which the order dated 10.03.2017, was issued for the transfer of the lease. 6. On 30.04.2020, a demand notice was issued by the Respondent-Corporation for the differential amount payable towards the transfer fee, wherein it was stated that if such payment was not made, the same would be termed as arrears of land revenue to be recovered at the rate of 18% interest and the action as contemplated in the terms and conditions of the Tripartite Deed dated 24.03.2017, would be undertaken. 7. 7. The Respondent-Corporation also issued demand notice dated 08.05.2020 for payment of lease rent and in this notice also, it was indicated that if there was a failure to pay the amount as demanded, it would be termed to be arrears of land revenue recoverable with an additional 18% interest and action contemplated under the terms and conditions of the Tripartite Deed dated 24.03.2017, would be undertaken. This demand notice was issued in respect of arrears of the lease rent, ignoring the representations submitted by the Petitioner for reconsideration of the rate applicable by treating the plot of land as underdeveloped plot. 8. The aforesaid demand notices are the subject matter of challenge in the present Writ Petition. The Respondent-Corporation filed its affidavit in reply and justified the demand notice for differential transfer fees on the ground that the amended Regulations applied and that it was due to inadvertence that less amount was charged as transfer fee when the order dated 10.03.2017 was issued in favour of the Petitioner. It was also sought to be contended that the differential Transfer fees was payable even if the unamended Regulations of 2014 were to be applied. 9. Mr. S. S. Kantak, learned Senior Counsel appearing along with Mr. Jitendra Supekar, the learned Counsel for the Petitioner, submitted that the Respondent-Corporation was not justified in issuing demand notice for differential transfer fees on the ground that the amended Regulations applied. It was submitted that the Citizens Charter of the Respondent-Corporation itself specifically states that the relevant date of applicability of transfer fee will be the date of application made by the party for transfer of plot. By inviting attention to various documents on record, the learned Senior Counsel submitted that the date of application of the Petitioner in the present case was 11.03.2015 and, admittedly, the amended Regulations came into force on 22.12.2016. On this basis, it was submitted that the amendment could not apply retrospectively and that, therefore, the Respondent-Corporation was not justified in claiming differential transfer fee. 10. It was further submitted that the contentions regarding less transfer fee charged by the Respondent-Corporation, due to inadvertence, cannot be accepted because when the Tripartite Lease Deed was executed, the parties had entered into the Lease Deed based on certain documents, upon which, there was agreement in the minds of the parties. 10. It was further submitted that the contentions regarding less transfer fee charged by the Respondent-Corporation, due to inadvertence, cannot be accepted because when the Tripartite Lease Deed was executed, the parties had entered into the Lease Deed based on certain documents, upon which, there was agreement in the minds of the parties. The aspect of mistake of fact cannot be unilaterally claimed by the Respondent-Corporation to unjustly claim differential transfer fees. It was further submitted that even if the amended Regulations were to apply, there was no justification claiming differential transfer fee. It was further submitted that the documents on record indicated that the subsequent demand notice was issued only on the opinion of the Advocate General, thereby indicating that the demand notice was issued on the diktats of the Government of Goa. The learned Senior Counsel invited attention of this Court to various provisions of the Goa Industrial Development Act, 1965, to contend that the Corporation was manned by very senior officials and it could not be dictated by the Government of Goa, as had happened in the present case. On this basis, it was submitted that the impugned demand notice for the differential transfer fees deserved to be set aside. 11. As regards the demand notice issued for arrears of lease rent, it was submitted that the Petitioner had placed on record before the Respondent-Corporation a number of representations requesting that the rate of annual rent be revised on the lower side by treating the plot of land as underdeveloped land. There was no response to any of the representations. Therefore, the Petitioner requested for a direction to the Respondent-Corporation to decide the representations submitted on behalf of the Petitioner. 12. On the other hand, Shri A. D. Bhobe, the learned Counsel appearing for the Respondent-Corporation submitted that the order granting transfer of lease was issued on 10.03.2017 and the amendment in the Regulations was brought into effect on 22.12.2016, thereby indicating that as on the date of the issuance of the order, the amended Regulations applied. On this basis, it was submitted that there was no substance in the contentions raised on behalf of the Petitioner. It was submitted that on a proper application of the amended Regulations, the demand notice was wholly justified and that the Petitioner could not be permitted to take advantage of an inadvertent mistake on the part of the Respondent-Corporation. On this basis, it was submitted that there was no substance in the contentions raised on behalf of the Petitioner. It was submitted that on a proper application of the amended Regulations, the demand notice was wholly justified and that the Petitioner could not be permitted to take advantage of an inadvertent mistake on the part of the Respondent-Corporation. It was submitted that all such cases/orders for transfer of lease, issued after 22.12.2016, would be governed by the amended Regulations and to create an exception for the Petitioner, would not be in the interest of justice. The Petitioner was liable to pay such transfer fee as similarly situated parties, were liable to pay. It was sought to be argued that even if the unamended Regulations of 2014 applied, the differential transfer fees was payable. As regards arrears of annual lease rent, it was submitted that the request made on the part of the Petitioner was an afterthought and that there was no substance in the contention raised on behalf of the Petitioner in that regard. 13. The learned counsel for the rival parties filed written notes of arguments in support of their respective stands. 14. In order to appreciate the contentions raised on behalf of the Petitioner in respect of the demand notice issued by the Respondent-Corporation for a differential transfer fee, it would be necessary to refer to certain documents on record. It is undisputed that the Petitioner moved the transfer application before the Respondent-Corporation on 11.03.2015, specifically requesting the Corporation to process the transfer application. The Petitioner enclosed the necessary documents for processing of the application. The process itself took some time because, as noted above, initially, the Corporation had expressed that it was unable to consider the request of the Petitioner. But, thereafter, the Government of Goa granted approval for such transfer of Lease Deed. Eventually, the Respondent-Corporation issued an order dated 10.03.2017 for transfer of the Lease Deed. This was after a letter dated 09.03.2017 was issued to the Petitioner, demanding transfer fees of Rs. 6,35,59,048/-, to enable the Respondent-Corporation to issue the transfer order. It is undisputed that on 10.03.2017, the amount demanded by the Respondent-Corporation was deposited through RTGS. Eventually, the Respondent-Corporation issued an order dated 10.03.2017 for transfer of the Lease Deed. This was after a letter dated 09.03.2017 was issued to the Petitioner, demanding transfer fees of Rs. 6,35,59,048/-, to enable the Respondent-Corporation to issue the transfer order. It is undisputed that on 10.03.2017, the amount demanded by the Respondent-Corporation was deposited through RTGS. In pursuance of the amount deposited and the specific order dated 10.03.2017, on 24.03.2017, the aforesaid Tripartite Deed of Lease was executed between the Petitioner, the Respondent-Corporation, and M/s. Meta Copper and Alloys Ltd, as the confirming party. 15. The most crucial aspect in the present case is that the date of the transfer application moved by the Petitioner was undisputedly 11.03.2015. The Citizens Charter of the Respondent-Corporation, which was not disputed by the learned Counsel appearing for the said Respondent, specifically states that the relevant date for applicability of transfer fee will be the date of the application made by the applicant for transfer of plot. Therefore, for all purposes, concerning the applicability of the transfer fee, the relevant date in the present case is 11.03.2015. This is further supported by the fact that the letter dated 09.03.2017, issued by the Respondent-Corporation, asking the Petitioner to deposit the aforesaid amount of Rs.6,35,59,048/-towards transfer fees also specifically referred to the aforesaid application dated 11.03.2015 submitted by the Petitioner. Even the order dated 10.03.2017, issued by the Respondent-Corporation for transfer of the Lease Deed specifically referred to the application dated 11.03.2015. The Tripartite Deed of Lease dated 24.03.2017, executed between the Petitioner, Respondent-Corporation and the aforesaid confirming party, at paragraph H specifically referred to the aforesaid application dated 11.03.2015 moved by the Petitioner. 16. Therefore, there can be no doubt about the fact that in terms of the Citizens Charter of the Respondent-Corporation itself, the relevant date for applicability of transfer fee would be the date of the application which, in the present case, was 11.03.2015. There is also no dispute about the fact that the amendment in the Goa-IDC Regulations 2014, came into effect on 22.12.2016. Therefore, on this ground itself, it becomes clear that the amendment to the Regulations cannot apply to the case of the Petitioner. This shows that the amount demanded by the Respondent-Corporation on 09.03.2017 and duly deposited by the Petitioner on 10.03.2017 was by application of unamended Regulations to the case of the Petitioner. Therefore, on this ground itself, it becomes clear that the amendment to the Regulations cannot apply to the case of the Petitioner. This shows that the amount demanded by the Respondent-Corporation on 09.03.2017 and duly deposited by the Petitioner on 10.03.2017 was by application of unamended Regulations to the case of the Petitioner. As this Court has concluded that the amendment brought about in the Regulations dated 22.12.2016 is not applicable to the case of the Petitioner, there is no occasion for this Court to go into the contentions raised on behalf of the rival parties on the question as to whether the amount of transfer fees payable as per the amended Regulations would be any different from the amount actually charged from the Petitioner. 17. Insofar as the question as to whether the Respondent-Corporation acted on the diktats of the Government of Goa and whether the Respondent-Corporation could justify its decision only on the basis of the direction issued by the Government of Goa, the same is rendered irrelevant in view of the fact that the amendment itself is found to be inapplicable to the facts of the present case. Therefore, it is found that the impugned demand notice dated 30.04.2020 issued by the Respondent-Corporation for differential amount towards transfer fee is liable to be quashed. 18. In the reply affidavit filed on behalf of the Respondent-Corporation the demand for differential transfer fees was sought to be justified by claiming that even under the unamended Regulations of 2014, the Respondent-Corporation was entitled to claim higher transfer fees and that the amount claimed in the impugned notice was therefore justified. It is by now fairly well settled that the validity of an order passed by a statutory authority is to be judged on the basis of the reasons stated in the order. The reasons cannot be supplemented by filing affidavits to justify the order. In the case of Mohinder Singh Gill Vs. Chief Election Commissioner 1978 (1) SCC 405 , the Honble Supreme Court held as follows: "8. The second equally relevant matter is that when a statutory functionary makes an order based on certain grounds, its validity must be judged by the reasons so mentioned and cannot be supplemented by fresh reasons in the shape of affidavit or otherwise. Chief Election Commissioner 1978 (1) SCC 405 , the Honble Supreme Court held as follows: "8. The second equally relevant matter is that when a statutory functionary makes an order based on certain grounds, its validity must be judged by the reasons so mentioned and cannot be supplemented by fresh reasons in the shape of affidavit or otherwise. Otherwise, an order bad in the beginning may, by the time it comes to court on account of a challenge, get validated by additional grounds later brought out. We may here draw attention to the observations of Bose, J. in Gordhandas Bhanji [Commr. of Police, Bombay v. Gordhandas Bhanji, AIR 1952 SC 16 ] : "Public orders, publicly made, in exercise of a statutory authority cannot be construed in the light of explanations subsequently given by the officer making the order of what he meant, or of what was in his mind, or what he intended to do. Public orders made by public authorities are meant to have public effect and are intended to affect the acting's and conduct of those to whom they are addressed and must be construed objectively with reference to the language used in the order itself." Orders are not like old wine becoming better as they grow older." 19. The said position of law has been followed consistently. Therefore, applying the same, this Court has refused to consider the reasons now sought to be supplemented in the reply affidavit and the written notes of arguments on behalf of the Respondent-Corporation that the differential demand towards transfer fees can be justified even by applying the unamended Regulations of 2014. The reason given in the demand notice is that the Regulations of 2014 as amended in the year 2016 applied and that therefore, the petitioner was liable to pay the differential Transfer fees. We have examined the validity of the impugned demand notice only on the said ground as stated therein. We say no more. 20. As regards the impugned demand notice dated 08.05.2020 issued by the Respondent-Corporation, it is brought to the notice of this Court that the Petitioner had submitted as many as six representations before the said Respondent-Corporation to re-consider the rate applicable towards annual lease rent. In these representations, the Petitioner has claimed that the rate of annual rent ought to be re-considered by treating the plot of land in question as an underdeveloped plot. In these representations, the Petitioner has claimed that the rate of annual rent ought to be re-considered by treating the plot of land in question as an underdeveloped plot. In support of the said contention, the Petitioner has placed before the Respondent-Corporation certain aspects as regards the condition of the land and the manner in which expenses were incurred for developing the same. The record shows that the Respondent-Corporation has not dealt with the representations. The Petitioner has prayed for a direction to the Respondent-Corporation to deal with and dispose of the aforesaid representations made by the Petitioner. 21. In the reply affidavit, the Respondent-Corporation has given reasons why the claims made in the representations are not tenable. At one place, it is also stated that therefore, the representations were not considered. This Court is of the opinion that a statutory Corporation like the respondent herein is expected to act in a responsible manner and to respond to such representations, so that the parties like the petitioner herein are at least made aware as to the reasons for the claim of the quantum of lease rent. Otherwise, the conduct of such statutory Corporations is rendered opaque and arbitrary. 22. Hence, this Court is of the opinion that the direction sought by the Petitioner in this context can be granted in the facts and circumstances of the present case, without any comment upon the issues sought to be raised by the Petitioner in that regard. Therefore, the Respondent-Corporation can be directed to consider the representations within a stipulated period of time and then to proceed further on the impugned demand notice dated 08.05.2020. 23. In view of the above, the Writ Petition is partly allowed. The impugned final notice dated 01.07.2020 and the demand notice dated 30.04.2020 issued by the Respondent-Corporation for payment of the differential amount towards transfer fees are quashed and set aside. 24. As regards the impugned final notice dated 01.07.2020 and demand notice dated 08.05.2020, pertaining to payment of arrears of lease rent by the Petitioner, the Respondent-Corporation is directed to consider and dispose of the representations submitted by the Petitioner for reconsideration of the rate towards annual rent, within a period of six weeks from today. 24. As regards the impugned final notice dated 01.07.2020 and demand notice dated 08.05.2020, pertaining to payment of arrears of lease rent by the Petitioner, the Respondent-Corporation is directed to consider and dispose of the representations submitted by the Petitioner for reconsideration of the rate towards annual rent, within a period of six weeks from today. The Respondent-Corporation may take further action in respect of the impugned final notice dated 01.07.2020 and demand notice dated 08.05.2020 pertaining to arrears of lease rent, after disposing of the aforesaid representations.