ORDER :

1. This Writ Petition is filed assailing the notice issued by respondent No. 2 requiring the petitioner to pay their Stamp duty chargeable in respect of the Agreements of Sale, dated 24.04.2011 in notice No. Imp/2406/2022, dated 01.11.2022, wherein the petitioner was required to pay Stamp duty under Article 6B of Schedule 1(A) of the Indian Stamp Act, 1899, as illegal and arbitrary.

2. It is the case of the petitioner that the said Agreements of Sale with possession, dated 24.04.2011, forwarded to respondent No. 2 for the purpose of impounding by collecting deficit Stamp duty in respect of the open lands admeasuring various extents and respondent No. 2, having considered the said documents, issued the impugned notice requiring the petitioner to pay deficit Stamp duty under Article 6(B) of Schedule 1(A) of the Indian Stamp Act, 1899.

3. According to the learned counsel for the petitioner, the agreements of sale in question are covering only open lands and as such the petitioner is liable to pay Stamp duty only under Article 6(A) of Schedule 1(A) of the Indian Stamp Act, 1899, but not under Article 6(B) of Schedule 1(A) of the Indian Stamp Act, 1899, as demanded by respondent No