JUDGMENT :

Dhananjaya Y. Chandrachud, J

1. Leave granted.

2. A citizen’s claim for the refund of stamp duty has found a winding path to this court. The appellant booked a residential apartment. There arose a dispute with the builder. It led to a consumer complaint. The litigation consumed time. The appellant was permitted to opt for a refund of the price. The claim for refund of stamp duty has been rejected by the revenue arm of the state on the ground that more than six months have elapsed. The Bombay High Court, agreeing with the decision found the claim to be stale. A simple claim for refund leads us to the complexities of a revenue sourcing law.

3. This appeal arises from a judgment dated 22 November 2018 of a Single Judge of the High Court of Judicature at Bombay. The Deputy Inspector General of Registration and Deputy Controller of Stamps, Pune rejected an application for refund of stamp duty filed by the appellant. The order of the authority was challenged in the exercise of the jurisdiction of the High Court under Article 226 of the Constitution. The petition has been dismissed.

4. On 24 April 2014, the appellant booked a residential flat, being Unit No 2001 admeasuring 1660 sq