JUDGMENT :

1. Heard Sri Prateek Kumar, learned counsel for petitioner and learned Standing Counsel appearing on behalf of State-respondents.

2. This is a case arising out of proceedings initiated under Section 47-A of Indian Stamp Act, 1899 as applicable in State of U.P. whereby deficiency of Stamp Duty was determined on execution of instrument in question i.e. a sale-deed.

3. The Prescribed Authority under Stamps Act took note of surroundings of land in question i.e. an agricultural land on eastern side, a non-agricultural land and an under construction building on western side, a hospital and other construction on northern side and a link road on southern side and further noted that within the radius of 50 mtrs. and 200 mtrs. of land in question, there were developed non-agricultural properties, and therefore, treated the land in question to be a non-agriculture land and accordingly deficiency of stamp duty was determined by impugned order dated 12.11.2020. An appeal thereof was also dismissed by another impugned order dated 22.03.2021.

4. Sri Prateek Kumar, learned counsel for petitioner has submitted that nature of land in question still remains to be an agricultural land. Appropri