Differences have surfaced between the Tata group and the government over handling of surplus land of Videsh Sanchar Nigam (VSNL).The major point of difference is who would be liable to pay stamp duty for transfer of property to a new entity - Hemisphere - created for the purpose.Panatone Finvest, which bought a controlling stake from the government in VSNL in 2002, is in the process of demerging the surplus land and transferring it to Hemisphere created by VSNL with three of its nominees on board.Panatone has resisted the move by the government to have three nominees on the board of Hemisphere.A VSNL official source said the shareholders agreement very clearly states that the strategic partner (Tatas) should facilitate the demerger. "It does not have any clause for any payment (of taxes) by the partner,"the officials said.Three months after Hemisphere was created with a equity of Rs 5 lakh by Panatone, the department of telecommunications (DoT) had sought to include government nominees on its board, top government officials said.They added that it was only in the fairness to have government representatives in an entity where the entire 773 acres of surplus land would be transferred for the benefit of the government.