By this writ petition, the petitioner has assailed the orders dated 29-06-2011 passed by the Additional District Magistrate (Finance & Revenue), Lucknow in Case No. 264/Stamp/2008 under Section 33/47-A of the Indian Stamps Act as well as the order dated 28-05-2012 passed by Chief Controller Revenue Authorities under Section 56(1) A of the Indian Stamps Act in Appeal No. 64 of 2011-12.

2. The facts in narrow compass are that the petitioner and M/s. Sahara India Commercial Corporation Ltd., had executed an instrument on 15-07-2005 known as Memorandum of understanding (MOU), where both the parties agreed that the petitioner will have a space about 9455.30 sq.ft. (Super area) in a commercial complex known as Saharaganj, Hazratganj, Lucknow on licence basis initially, for a period of three years and the said period shall also be renewable and the same has already been renewed for a total period of 9 years.

3. The petitioner has paid stamp duty of Rs. 100/- on the said instrument (MOU), by considering it as a deed of licence, but the stamp authorities considered the said instrument as a lease deed and demanded stamp duty of Rs. 33,93,500/-. The penalty was also imposed to the tune of