JUDGMENT :

1. The petitioner, a society registered under the Societies Registration Act purchased a property by means of a sale deed dated 29.10.1998, whereby agricultural plots no. 774, 775, 784, 785, 786, 787, 789 and 790 admeasuring 9 Bigha, 12 Biswa from a Co-operative Society for a total sale consideration of Rs. 25 Lakhs. The said land being agricultural land, the stamp duty was paid in terms of the Property Valuation Rules, valuing the property at Rs. 66,36,000/-, which was the prescribed rate by the Collector, Agra being Rs. 30 Lakhs per hectare for agricultural lands and consequently, the stamp duty was paid thereupon.

2. A notice was served upon the petitioners in exercise of powers under Section 47-A of the Stamp Act proposing to redetermine the stamp duty. The petitioner-society filed its objections specifying therein that the land in question was an agricultural land and the entire area in the vicinity was undeveloped and thus for the purposes of valuation, the property was valued on the rates specified for agricultural properties and thus requested that show cause notice be dropped. An affidavit was also filed by the petitioner-society specifically stating therein that