JUDGMENT

VIBHU BAKHRU, J.

1. The petitioner has filed the present petition, inter alia, praying that Section 54 of the Indian Stamp Act, 1899 (hereafter ‘the Act’), to the extent it provides for retention of 10% of the stamp duty, be declared as ultra vires of Articles 265 and 300A of the Constitution of India. The petitioner also impugns Section 54(c) of the Act as being ultra vires of Articles 14, 265 and 300A of the Constitution of India.

In addition, the petitioner assails the order dated 20.02.2019 passed by respondent no.2, Collector of Stamps/SDM (HQ) (hereafter ‘the Collector’) whereby, the petitioner’s application for a refund against E-stamp Certificate bearing No.IN-DL94299245494081N, was rejected on the ground that the said application was filed beyond the period of six months from the date of purchase of the E-stamp Certificate.

FACTUAL CONTEXT

2. The petitioner is a company registered under the Companies Act, 1956 and was intending to purchase a land admeasuring 18 Bighas and 09 Biswas, titled, Khasra No.31/11/1(2-6) 20/ 1 (4-00), 23/2 (3-04),24 (4-04) and 19/1(405), at village Rawta in Delhi (hereafter ‘the subject property’).

3. On 19.09.2014, the petitioner filed an app