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16. We therefore reiterate that immovable property can be legally and lawfully transferred/conveyed only by a registered deed of conveyance. Transac&ons of the nature of `GPA sales' or `SA/GPA/WILL transfers' do not convey &tle and do not amount to transfer, nor can they be recognized or valid mode of transfer of immoveable property. The courts will not treat such transac&ons as completed or concluded transfers or as conveyances as they neither convey &tle nor create any interest in an immovable property. They cannot be recognized as deeds of &tle, except to the limited extent of sec&on 53A of the TP Act. Such transac&ons cannot be relied upon or made the basis for muta&ons in Municipal or Revenue Records. What is stated above will apply not only to deeds of conveyance in regard to freehold property but also to transfer of leasehold property. A lease can be validly transferred only under a registered Assignment of Lease. It is &me that an end is put to the pernicious prac&ce of SA/GPA/WILL transac&ons known as GPA sales."