Hon’ble Arun Tandon, J.—These two connected writ petitions have been filed by the officers of the Life Insurance Corporation of India challenging the demand of stamp duty to the sum of Rs. 1,77,71,488/- raised by the Deputy Inspector General/Deputy Commissioner, Stamps, Kanpur Division, Kanpur vide order dated 29.11.2003 and the consequential demand notices dated 5.2.2007 and 22.2.2007.

2. Facts relevant for deciding these two petitions are as follows :

Life Insurance Company is a statutory Corporation created under the Life Insurance Corporation Act, 1936. The Corporation has its Zonal office at Kanpur Nagar.

For the purposes of execution of Life Insurance Policies for every sum of Rs. 1000/- insured a insurance stamp of the value of 40 paisa is required to be affixed on each policy bond. The Divisional Office at Kanpur made purchases of self adhesive insurance stamps from the registered stamp vendors of Maharashtra, between 19.4.1993 to 29th March, 2001 and is stated to have used the same on policy bonds issued by various Branch of Life Insurance Corporation under the Divisional Office at Kanpur. A dispute arose with regards to the genuineness of such insurance stamps purch