( 1 ) THE petitioner has approached this Court by means of the present petition, assailing the legality and propriety of the two orders -- one dated 20-2-1995 passed in proceeding under Section 47a (2) of the Stamp Act, 1899, by Additional District Magistrate (Finance and Revenue), Kanpur Nagar, levying stamp duty of Rs. 37,01,26,832-50/- and slapping a penalty of Rs. 30,53,167-50. 00 and the other dated 4-4-1995 passed by the Chief Controlling Revenue Authority in Stamp Revision No. 36 of 1995-96 Kanpur Nagar under Section 56 of the Stamp Act, preferred against the aforesaid order of the Additional Distt. Magistrate (Finance and Revenue), Kanpur Nagar. The revision has been allowed partly vide impugned order dated 4-4-1995 of the Chief Controlling Revenue Authority, setting aside the order passed by the Addl. District Magistrate (Finance and Revenue), Kanpur Nagar in so far as imposition of penalty was concerned and slightly modifying the order under revision as regards the stamp duty holding that the total stamp duty payable on the deed of conveyance dated 9 -6-1994 would be Rs. 36,68,08,887-50 -- at an estimated total value of Rs. 2,53,14,61,115/ -.

( 2 ) THE fact