Hon’ble Mrs. Sunita Agarwal, J.—Heard Shri S.K. Chaubey, learned counsel for the petitioner and learned standing counsel.

2. Petitioner has challenged the validity and legality of the order dated 8.10.2002 passed by Additional Collector (Administration) Allahabad as also the order dated 23.6.2001 passed by the Commissioner, Allahabad Division, Allahabad. Further prayer has been made in the nature of writ of mandamus commanding the respondents not to recover the amount of Rs. 74,440/- from the petitioner as deficiency of stamp duty.

3. By order dated 8.10.2002 deficiency of stamp duty and penalty has been imposed under Section 47 of the Stamp Act.

4. The facts giving rise to the present writ petition are that the petitioner had purchased land, namely Gata No. 848/2 area 5 Bishwa 10 Bishwansi situated in village Mauja Bamrauli Uparhar, Pargana and Teshil Sadar, District Allahabd through registered sale-deed dated 23.9.1997. The stamp duty paid was Rs. 8,250/- the land was purchased as mentioned in the sale-deed for the agricultural purposes.

5. The document was placed for registration before the Sub- registrar on 23.8.1997, the Sub-registrar referred the matter to the Distric