JUDGMENT :

1. Heard Sri Kamal Shankar Ojha, learned counsel for the petitioner and Sri Sanjay Goswami, learned Additional Chief Standing Counsel for the respondents-State.

2. The petitioner has assailed the order dated 21.06.2011 passed by the learned adjudicating authority/District Magistrate/Collector (Stamp), Sonebhadra, determining the stamp liability of the petitioner on the instrument in issue as well as the order dated 22.03.2012 passed by the learned appellate authority/Commissioner, Vindhyachal Mandal, Mirzapur, affirming the order of the learned adjudicating authority/District Magistrate/Collector (Stamp), Sonebhadra.

3. The learned adjudicating authority/ District Magistrate/Collector (Stamp), Sonebhadra in the impugned order dated 21.06.2011 has placed exclusive reliance on a report submitted by the Additional District Magistrate (Finance & Revenue), Sonebhadra, after the inspection of the disputed premises. The report dated 30.09.2009 was submitted in the aftermath of the sale-deed. The sale-deed was executed on 20.04.2009. The petitioner had tendered his objection to the aforesaid inspection report. While finding against the petitioner, the adjudicating authority held th