JUDGMENT :

SAUMITRA DAYAL SINGH, J.

1. Heard Shri Pramod Kumar Sinha, learned counsel for the petitioner and Shri Sanjay Goswami, learned Additional Chief Standing Counsel along with Shri Dinesh Kumar Gupta, learned Additional Chief Standing Counsel, for the revenue.

2. Present writ petition has been filed to challenge the order dated 27.7.2017 passed by Commissioner, Moradabad Division, Moradabad, in Revision No. C-20171300423 filed by the petitioner, under Section 56(1) of the Indian Stamp Act 1899 (hereinafter referred to as the Act), against the order of the Collector, Rampur, dated 30.12.2016 passed in proceedings under Section 33/47 of the Act (State vs. Harbhajan Singh). The Revision Authority has dismissed the aforesaid Revision and confirmed the deficiency of stamp duty determined together with interest and, penalty imposed by the Collector, Rampur, vide his order dated 30.12.2016. Thus, deficiency of stamp duty Rs. 12,36,800/- and interest liability @ 1.5% per month together with registration fee Rs. 100/- and penalty Rs. 12,36,700/- has been confirmed, on a photocopy of the document dated 12.11.2013, described as agreement to sell.

3. The undisputed facts of the case are, th