By an earlier order dated reported in Suraj Lamp Industries Pvt Ltd vs State of Haryana Anr - SCC we had referred to the ill - effects of what is ... known as General Power of Attorney Sales for short GPA Sales or Sale Agreement General Power of Attorney Will transfers for short SA GPA WILL transfers Both the descriptions are misnomers as there cannot be a sale by execution of a power of attorney nor can there be a transfer by execution of an agreement of sale and a power of attorney and will As noticed in the earlier order these kinds of transactions were evolved to avoid prohibitions conditions regarding certain transfers to avoid payment of stamp duty and registration charges on deeds of conveyance to avoid payment of capital gains on transfers to invest unaccounted money black money and to avoid payment of unearned increases due to Development Authorities on transfer