Hon’ble Sudhir Agarwal, J.—Heard Sri Dinesh Pathak, learned counsel for the petitioner and learned Standing Counsel for the respondents.

2. It is contended that petitioner purchased an agricultural land in Gata No. 61, area 0.37 acre vide sale-deed dated 19.5.1997 but respondents proceeded under Section 47-A of Indian Stamp Act, 1899 (hereinafter referred to as “Act, 1899”) alleging that subsequent commercial user shows that land was purchased for commercial purposes and liable for stamp duty on the rates admissible to commercial rates though at the time of transaction, it was an agricultural land and has been purchased accordingly by paying market value of agricultural property as existed.

3. From the impugned order dated 5.8.2000, it is evident that a spot inspection report was submitted by Tehsildar, Etawah on 16.7.1999 i.e. after more than two years and position as he found at that time has been taken into consideration to determine whether the instrument discloses true market value at the time of registration.

4. The subsequent user would not justify inference that the true market value is something higher than what it was stated in the instrument and there was deficiency