( 1 ) THE petitioner had purchased 500 square meters of land out of plot No. 412/0/15-0 situated in phulpur town area, Allahabad under registered sale deed on 1st May. 1992, setting forth Rs. 50. 000 as market value of the property. Proceeding was initiated by the Collector for determining the market value of the property under Section 47a, read with Section 33 of the stamp Act. By an order dated 8th February. 1993. the Collector had held that the market value was Rs. 1,79. 970 and, therefore, the stamp duty payable was Rs. 16. 240 and directed the payment of the difference by the petitioner. A revision being Stamp Revision No. 111 of 1993-94 was preferred by the petitioner. By an order dated 17th January, 1996. the revision was dismissed. It is this order which is subject-matter of challenge in this petition.

( 2 ) POINTING out from the impugned orders, Mr. N. D. Kesari, learned counsel for the petitioner contends that on the revenue records, the land was recorded as agricultural land with bhumadhari interest. He also points out that the boundary of the land shows that the land surrounding the disputed plot are agricultural lands. Unless there is a declaration under