A Victorian tribunal has slapped down a $3.8 million stamp duty challenge by Simon Pitard and failed development company Steller, finding they failed to read instructions on a form correctly and were liable for unpaid revenue on as many as 35 land purchases.

The Victorian Civil and Administrative Tribunal last week upheld the State Revenue Commissioner's assessment made against Mr Pitard and four Steller entities after finding they had fallen foul of sub-sales provisions by conducting development work on land contracted to one purchaser and transferred to someone else at settlement under a nominee process.