Mohit Kumar Shah, J. – The present writ petition has been filed for quashing the order dated 22.4.2019, passed by the Assistant Inspector General Registration, Patna Division, Patna (Respondent No. 2) in Case No. 404 of 2017, whereby and whereunder the petitioner has been directed to pay deficit stamp duty to the tune of Rs. 14,99,930/- along with a fine of Rs. 1,49,993/-. The petitioner has also prayed for quashing the Appellate order dated 22.1.2021, passed by the learned Divisional Commissioner, Patna, in Stamp Appeal Case No. 143 of 2019.

2. The brief facts of the case, according to the petitioner, are that the petitioner purchased a land, appertaining to Thana No. 40, Tauzi No. 5127, Thana Code No. 092, Khata No. 250, Survey Plot No. 425(Part), situated at Bhusaula Danapur, P.S.- Phulwarisharif, District-Patna, vide a sale deed dated 7.9.2017, which was registered on the same day i.e. 7.9.2017. Thereafter, the Sub-Registrar had found that the stamp duty had been paid by treating the land in question to be that of residential category, instead of commercial category, since upon enquiry it had transpired that the land in question is situated on the main road, hence, he had referr