ORDER : N.V. Shravan Kumar, J. This writ petition is filed seeking the following prayer: “to direct the respondents holding that the impugned notice Lr.No.346/SRO Kapra/2018 dated 26.11.2018 as illegal arbitrary and depriving her rights to get the property bearing plot No.90 in SY.No.100, Baba Nagar, Mallapur Village, Uppal Mandal, Medchal Malkajgiri District, admeasuring 120 Sq,Yards or 100.32 Sq Metrs out of 433.39 Sq. Yards with a plinth area of 900 sq feet with Rcc Roof and in violation of Sec 27 of Andhra Pradesh Revenue Recovery Act of Act II of 1864 and section as well as registration Act and consequently direct the respondents to register the document pending P48/2018 dated 26.11.2018 of Sub Registrar in respect of admeasuring 120 Sq Yards are 100.32 Metrs out of 433 39 Sq yards with a plinth area of 900 Sq feet with RCC Roof pending disposal of the writ petition.” 2 . Heard Sri N. Bhujanga Rao, learned counsel appearing for the petitioner, learned Assistant Government Pleader for Revenue appearing for respondent Nos.1 to 4 and learned Assistant Government Pleader for Sales Tax appearing for respondent No.5. Perused the record. 3 . Facts in brief are as follows: Petitioner submits that she purchased the subject property from one Mr.Chevella Raju through his registered Agreement Of Sale – cum – General Power of Attorney holder Mr.Bellamkonda Venkaiah, S/o.Bellamkonda Venkaiah S/o.B.Yanadri by paying entire sale consideration of Rs.11,10,000/- as mentioned in sale deed dated 23.10.2018. Petitioner’s further case is that after paying Registration charges together with Stamp Duty and other Miscellaneous charges, the petitioner along with her Vendors presented the Document for Registration of the Sale Deed dated 23.10.2018 before the Respondent No.4 and the same was received and kept pending vide Document No.P.48/2018. 4 . Thereafter, the petitioner made a request on 22.11.2018 to respondent No.4 to register the aforesaid sale deed and in reply respondent No.4 had issued impugned letter dated 26.11.2018 refusing to register the sale deed and informed the petitioner with regard to the attachment of the property, which was Published under Gazette Notification issued by the then District Collector, Rangareddy District vide No.30 dated 08.07.2015 vide Lr.No.D/4/No.03/2018-19, dated 25.08.2018 notifying the Attachment of the property of one M/s.Subnil Packing Machines Private Limited comprising of open Plot No.90, Survey 100, Mallapur, Babanagar, Ranga Reddy District. (hereinafter called as ‘subject property / scheduled property’) 5 . (hereinafter called as ‘subject property / scheduled property’) 5 . It is further submitted that the said notification was issued by the Respondent No.2 in view of non-payment of taxes by the said M/s.Subnil Packing Machines Private Limited for an amount of Rs.1,94,68,553/- and that though several steps were initiated, Government was unable to collect arrears of taxes and thereby, having no other alternative to the recourse, the Provisions of A.P. Revenue Recovery Act, were invoked. 6 . It is further submitted that subsequent to the issuance of the aforesaid attachment of the property vide notification No.30 dated 10.07.2015, the Assistant Commissioner (Sale Tax) Musheerabad Circle, Hyderabad – respondent No.5, had addressed a letter dated 25.08.2018 to Respondent No.4 intimating about the Attachment of the property for non-payment of arrears of taxes of Rs.1,94,68,553/- and steps were initiated for collection procedure under Revenue Recovery Act, 1864 and requested to stop registration or change of title. It is further submitted that though the Respondents have issued the notification the same was not published and have not complied the requirements of Section 27 of A.P. Revenue Recovery Act, 1864. For Ready reference Sec. 27 of the Act is extracted as under: “The attachment shall be effected by affixing a notice thereof to some conspicuous part of the land. The notice shall set forth that unless the arrears, with interest and expenses, be paid within the date therein mentioned, the land will be brought to sale in due course of law. The attachment shall be notified by public proclamation on the land and by publication of the notice in the District Gazette." 7 . It is further submitted that M/s.Subnil Packing Machines Private Limited had purchased the subject property under a Registered Sale Deed vide Document No.10485 of 2004 and had mortgaged the property by obtaining loan from Andhra Bank, SME Nacharam Branch, Hyderabad and the said loan was repaid and Mortgage was released. Thereafter, the said M/s.Subnil Packing Machines Private Limited had executed a Registered Sale Deed on 18.08.2017 vide Document No.3452 of 2017 for an extent of 120 Sq.yards out of 433 Sq. yards to one Mr.Chevella Raju. Thereafter, the said M/s.Subnil Packing Machines Private Limited had executed a Registered Sale Deed on 18.08.2017 vide Document No.3452 of 2017 for an extent of 120 Sq.yards out of 433 Sq. yards to one Mr.Chevella Raju. Then the said M/s.Subnil Packing Machines Private Limited had also executed another Registered Sale Deeds in favour of Mr.Alkapalle Venkanna, Mr.Gunti Mallesham and an Agreement of Sale Cum- General Power of Attorney in favour of Mr.Tattipalli Ilaiah and Registered Sale Deed in favour of Mr.Gudumakhtla Bal Reddy vide Document Nos.3453/17 3454/17, 3159/17 and 5400/17, respectively. 8 . Thereafter, the said Mr.Chevella Raju, alleging to be the owner and the Possessor of the land had executed a Registered Agreement of Sale cum- Power of Attorney in favour of Mr.Bellam Konda Venkaiah vide Document No.1245/18, dated 05.03.2018. Basing on the said Agreement of Sale -cum-General Power of Attorney, Mr.Chevella Raju representing Mr.Bellam Konda Venkaiah, had sold the said property to the petitioner by sale deed dated 23.10.2018, which was presented for Registration and the said Document, was kept pending vide Document No.P.48/2018. Thereafter, impugned letter No.346/SRO KAPRA/2018 Dated 26-11-2018 was issued to the petitioner. 9 . The main grievance of the petitioner is that the respondents having allowed and accepted various Sale transactions and regularized series of documents, as mentioned supra and at this juncture cannot refuse to register the Sale Deed in respect of the property purchased by the petitioner. It is the further submitted that the petitioner is a bonafide Purchaser of the Scheduled Property and keeping the sale deed pending vide Document No.P.48/18 would deprive the petitioner’s claim over the subject property and amounts to discrimination as far as the sale transaction of the petitioner is concerned. Questioning the same, petitioner filed the present Writ Petition. 10 . A counter has been filed by respondent No.5 stating that one M/s.Subnil Packing Machine Private Limited, was registered under the provisions of Telangana Value Added Tax Act , 2005, and is on the rolls of respondent No.5. Questioning the same, petitioner filed the present Writ Petition. 10 . A counter has been filed by respondent No.5 stating that one M/s.Subnil Packing Machine Private Limited, was registered under the provisions of Telangana Value Added Tax Act , 2005, and is on the rolls of respondent No.5. The said M/s.Subnil Packing Machine Private Limited fell in arrears of tax and penalty to the assessment order 15.06.2015 was made under the provisions of VAT Act for the period 2011-12 to 2014-15, raising a tax demand of Rs.43,85,573/- and penalty order dated 13.07.2015 for a sum of Rs.10,96,384/- and under the CST Act assessments for the period 2006-07 to 2011-12, raising a demand of Rs.1,39,61,500/-, as such, the total tax due from the dealer was Rs.1,94,68,553/-. 11 . It is further submitted that in spite of repeated demands, M/s.Subnil Packing Machine Private Limited did not pay the arrears and the company had immovable property in Plot No.90, Sy.No.100, Mallapur, Babanagar, RR District to an extent of 433 Sq. yds., and the said immovable property was within the territorial jurisdiction of the Deputy Commercial Tax Officer (DCTO), Nacharam Circle. In view of the same, the respondent authorities have initiated recovery proceedings by invoking the provisions of the Revenue Recovery Act, 1864 by issuing Form No.I (Distraint Order) on 17.03.2015 to the dealer M/s.Subnil Packing Machine Private Limited. As there was no response, the DCTO issued Form No.IV (demand prior to attachment of land & Building) dated 18.03.2015 and Form No.V (Notice of attachment) dated 25.04.2015, which was published in Ranga Reddy District Gazette on 08.07.2015. It is further submitted that when there was no response Form No.VII (Notice of sale of land) was also issued on 27.02.2016 and the same was served on 04.03.2016. 12 . It is further submitted that in order to defraud the Tax Department, the said M/s.Subnil Packing Machines Private Limited executed an Agreement of Sale-Cum- General Power of Attorney with possession in favour of one Ms.Tattipalli Ilaiah vide Document No.3159 of 2017 dated 29.07.2017 in respect of the land admeasuring 433 Sq. 12 . It is further submitted that in order to defraud the Tax Department, the said M/s.Subnil Packing Machines Private Limited executed an Agreement of Sale-Cum- General Power of Attorney with possession in favour of one Ms.Tattipalli Ilaiah vide Document No.3159 of 2017 dated 29.07.2017 in respect of the land admeasuring 433 Sq. Yards (Plot No.90) in Sy.No.100 situated at Baba Nagar, Mallapur, Uppal Mandal, Medchal Malkajgiri District and the said Mr.Tattipalli Ilaiah, who is GPA holder and the dealer of M/s.Subnil Packing Machines Private Limited, is very well aware of the fact that the subject property has been put to attachment under Section 27 of the Revenue Recovery Act and the same was also issued in Gazette Notification dated 10.07.2015. In view of the same, the very execution of Agreement of Sale-Cum-General Power of Attorney with possession in favour of Mr.Tattipalli Ilaiah by M/s. Subnil Packing Machines Private Limited, is only to defraud the Revenue Department. 13 . It is further submitted that execution of all registered sale deeds is an Act of continuation of defrauding the revenue authorities and all the aforesaid transactions are admittedly made subsequent to the publication of Gazette notification dated 10.07.2015, which was issued in terms of Revenue Recovery Act. 14 . It is further submitted that when the Department observed the said illegal transactions, respondent No.5 had issued a letter dated 25.08.2018 to Respondent No.4 intimating the attachment of scheduled property for non- payment of arrears of taxes of Rs.1,94,68,553/-. During the said period Mr.Chevalla Raju through his GPA holder i.e., Mr.Bellamkonda Venkaiah had made one more attempt in executing the sale deed in favour of Mr.Tattipalli Komuramma (petitioner herein) towards the land admeasuring 120 Sq. Yards in Plot No.99 in Sy.No.100 situated at Baba Nagar, Mallapur, Uppal Mandal, Medchal Malkajgiri District that too when the said land is under attachment in terms of Section 27 of Revenue Recovery Act and also Gazette Publication issued in Form No.5 vide notification dated 10.07.2015. 15 . It is further submitted that as per Section 26 of the VAT Act, the property of defaulting VAT dealer by operation of law is subject to first charge of the tax due or any other sum payable by him under the Act. Section 27(1) of the VAT Act places on the defaulting dealer the onus to prove that the transfer was not with an intention to defraud revenue. Section 27(1) of the VAT Act places on the defaulting dealer the onus to prove that the transfer was not with an intention to defraud revenue. The person who has purchased property from a defaulting dealer must be held to have constructive notice of the charge in view of Section 26 of the AP VAT Act and any transfer of the subject property, by defaulting dealer is void and the revenue is entitled to recover VAT even for the assessment period subsequent to the transfer of the property. 16 . It is further submitted that as per Section 27(1) of the TVAT Act without using express words, in effect, provides that the charged property can be brought to sale in enforcement of the charge even at the hands of a bonafide transferee without notice of the charge unless the defaulting dealer discharges the onus and proves that the transfer of property was not with the intention to defraud revenue. It is only if the defaulting dealer proves that transfer of the property which is subject to first charge under Section 26 of the A.P. VAT Act, is not with the intention to defraud revenue, would the transferee be entitled to claim title over the subject property for, otherwise, such transfer of property is void. Where property has been transferred and the defaulting dealer who has transferred the property which is subject to a statutory charge under Section 26 of the A.P. VAT Act, does not discharge the onus of proving that the transfer was not with the intention to defraud revenue, a person who has purchased such immovable property from the defaulting dealer, cannot claim any protection 17 . It is further submitted that respondent No.5 had complied with all the ingredients / requirements stipulated in Section 27 of the Revenue Recovery Act and once a notification is published in the Gazette, it cannot be contended that one has no notice of the contents of the publication. It is further submitted that the person who has purchased property from a defaulting dealer must be held to have constructive notice of the charge in view of Section 26 of the AP VAT Act and any transfer of the subject property, by defaulting dealer is void and the revenue is entitled to recover VAT even for the assessment period subsequent to the transfer of the property. It is settled law that publication in the Gazette is deemed to be notice to all concerned and a letter to the sub-Registrar is only to avoid further litigation and to save innocent purchasers. ANALYSIS AND CONCLUSION : 18 . On a perusal of the impugned letter / rejection order dated 26.11.2018, communicated to petitioner it would reveal that the Sub-Registrar, Kapra, Medchal-Malkajgiri district – respondent No.4 has issued the said order based on the attachment order issued by the District Collector, Ranga Reddy District – respondent No.2 vide Gazette Notification vide No.30, dated 08.07.2018 with reference No.Mubd/D4/No.:03/2018-19 dated 25.08.2018 which was communicated by the Assistant Commissioner (S.T.), Musheerabad – Circle, Hyderabad – respondent No.5, wherein it was informed to respondent No.4 that the scheduled property was under attachment and thereby by noting the details of the communication, the said document was Kept pending vide P.No.48/2018 dated 23.10.2018. 19 . At this juncture, it is relevant to refer to Section 22-A of the Registration Act , 1908, which deals with ‘ Prohibition of Registration of certain documents ’. The relevant portion of Sections 22-A (1) (e) of the Registration Act , 1908 reads as follows: “(1) The following classes of documents shall be prohibited from registration, namely (a) … … … (b) … … … (c) … … … (d) … … … (e) any documents or class of documents pertaining to the properties the State Government may, by notification prohibit the registration in which avowed or accrued interests of Central and State Governments, Local Bodies, Educational, Cultural, Religious and Charitable Institutions, those attached by Civil, Criminal Revenue Courts and Direct and Indirect Tax Laws and others which are likely to adversely affect these interests.” 20 . A Division Bench of this Court in M/s.Inveeta Technologies Private Limited and others v. Government of Andhra Pradesh , [ 2024 (1) ALT 272 ] had upheld the validity of Section 22-A of the Registration Act , 1908. At paragraph No.28 of the aforesaid order a reference was taken to the Full Bench judgment of this Court in Vinjamuri Rajagopala Chary vs. Revenue Department , 2016 (2) ALD 236 (FB) : 2015 SCC OnLine Hyd 407 which has dealt with various Clauses of Section 22-A of the Registration Act , 1908. At paragraph No.28 of the aforesaid order a reference was taken to the Full Bench judgment of this Court in Vinjamuri Rajagopala Chary vs. Revenue Department , 2016 (2) ALD 236 (FB) : 2015 SCC OnLine Hyd 407 which has dealt with various Clauses of Section 22-A of the Registration Act , 1908. For the purpose of the present case, relevant Clause-vi in paragraph No.28 is extracted for reference: “… … (vi) While dealing with clause (e) of Section 22A(1) of the Act, it was held that the provision should be given fair, pragmatic, commonsense and purposive interpretation so as to fulfil the object of the enactment. The provision intends to cover not only attached property but also the property in which Central and State Government is having avowed and accrued interest.” 21 . In Paragraph No.30 of the aforesaid common order a further reference was taken to paragraph Nos.155 and 156 of a Full Bench decision in Vinjamuri Rajagopala Chary’s case and the relevant paragraph No.156 (vi) is extracted for facility: 156. We, thus, summarize our conclusions and issue directions as follows : - … … … (vi) The properties covered under clause (e) of Section 22-A shall be notified in the official gazette of the State Governments and shall be forwarded, along with the list of properties, and a copy of the relevant notification/gazette, to the concerned registering authorities under the provisions of Registration Act and shall also place the said notification/gazette on the aforementioned websites of both the State Governments. The Registering authorities shall make available a copy of the Notification/Gazette on an application made by an aggrieved party. 22 . Respondent No.4 has issued the rejection / impugned letter, dated 26.11.2018 on the basis of notification issued by respondent No.2 vide No.30 dated 08.07.2015 with reference to proceedings No.Mubd/D4/No.:03/2018-19 dated 25.08.2018 issued by respondent No.5. As such the impugned notice, dated 26.11.2018 refusing to register the pending document is in accordance with the provisions of Section 22-A (1)(e) of the Registration Act , 1908 and also in terms of Rule 242 of the Registration Rules under the Registration Act , 1908, which reads as under: “242. As such the impugned notice, dated 26.11.2018 refusing to register the pending document is in accordance with the provisions of Section 22-A (1)(e) of the Registration Act , 1908 and also in terms of Rule 242 of the Registration Rules under the Registration Act , 1908, which reads as under: “242. The Registering Officer shall refuse to register any document relating to a property which is included in the lists furnished under Rule 238, 239, 240 and in the lists notified by the Government under section 22-(A)(1)(e) or section 22-A(4).” 23 . That apart, it is further to be noted that in the pending document (i.e., sale deed dated 23.10.2018) vide P.48/2018, the petitioner is only a buyer and one Mr.Chevella Raju is the vendor / seller of the petitioner. Whereas the said vendor of the petitioner had never challenged the action of respondent No.4 in keeping the said document pending. It is pertinent to note that in the sale deed dated 23.10.2018, the vendor claims his ownership by virtue of registered document No.3452/2017 dated 18.08.2017. The said document is registered subsequent to the notice of attachment dated 10.07.2015 issued by the District Collector, Ranga Reddy district in accordance to Section 27 of the Andhra Pradesh Revenue Recovery Act , 1864. At this juncture, it is also relevant to refer Article 300-A of the Constitution of India extracted for reference: “Article 300A in Constitution of India 300A. Persons not to be deprived of property save by authority of law” 24 . The vendor of the petitioner as on the date of execution of the sale deed dated 23.10.2018 has no better right / title to convey the property to the petitioner. The Hon’ble Apex Court in Sanjay Sharma v. Kotak Mahindra Bank Ltd. , and others, 2024 SCC Online SC 4589 at paragraph No.27 held that until registration is effected, ownership is not transferred, which is extracted for reference: “27. Section 54 of the Transfer of Property Act, 1882, defines a “sale” as the transfer of ownership in exchange for a price that is either paid, promised, or part-paid and part-promised. This provision further describes the manner in which a sale is effected. It stipulates that, in the case of tangible immovable property valued at one hundred rupees or more, the transfer can be made only through a registered instrument. This provision further describes the manner in which a sale is effected. It stipulates that, in the case of tangible immovable property valued at one hundred rupees or more, the transfer can be made only through a registered instrument. The use of the term “only” signifies that, for tangible immovable property valued at one hundred rupees or more, a sale becomes lawful only when it is executed through a registered instrument. Where the sale deed requires registration, ownership does not pass until the deed is registered, even if possession is transferred, and consideration is paid without such registration. The registration of the sale deed for an immovable property is essential to complete and validate the transfer. Until registration is effected, ownership is not transferred.” 25 . The document as claimed by the vendor vide registered document No.3452/2017 dated 18.08.2017 is not a valid transfer as it is against the provisions of Section 27 of the Andhra Pradesh Revenue Recovery Act , 1864. The petitioner document is only received by the respondent No.4 and assigned pending P.No.48/2018 and the said document is not registered and released and without registration of the document, the petitioner cannot get right over the property as such the petitioner has no right to question the impugned letter dated 26.11.2018 issued by respondent No.4. The vendor / seller of the petitioner never questioned the impugned letter dated 26.11.2008. It is further to be noted that Article 300A of the Constitution of India can be invoked only by the owner of the property and as on the date of filing the Writ Petition, petitioner is not the owner of the subject property. The petitioner ought to have taken steps against her vendor in terms of the Agreement of Sale Deed dated 23.10.2018 (P.No.48/2018). On this ground also the writ petition deserves dismissal. 26 . In view of the same, the petitioner ought to have approached competent Court of law for redressal of her grievance in terms of agreement dated 23.10.2018. Instead of seeking such remedy, filed the present Writ Petition questioning the impugned rejection letter, dated 26.11.2018 issued by respondent No.4. In view of the same, this Court observes that the Impugned notice Lr.No.346/SRO Kapra/2018 dated 26.11.2018 warrants no interference. Instead of seeking such remedy, filed the present Writ Petition questioning the impugned rejection letter, dated 26.11.2018 issued by respondent No.4. In view of the same, this Court observes that the Impugned notice Lr.No.346/SRO Kapra/2018 dated 26.11.2018 warrants no interference. The respondents have rightly followed the due process as contemplated under the provisions of the Registration Act , 1908 and relevant Rules and A.P. Revenue Recovery Act, 1864 and provisions of TVAT Act, 2005. For the reasons stated above, this writ petition is devoid of merits, fails and is liable to be dismissed. 27 . Accordingly, this Writ Petition is dismissed. There shall be no order as to costs. Miscellaneous applications, if any pending, shall stand closed.