(1.) Since pleadings are complete and learned counsel for the parties are ready to argue the matter finally, therefore, it is finally heard.
(2.) By the instant petition filed under Article 226 of the Constitution of India, the petitioner is questioning the legality, validity and propriety of the order dtd. 18/5/2021 (Annexure P/1) passed by the respondent no.1 whereby the petitioner has been directed to deposit an amount of Rs.46,61,667.00 as deficit stamp duty and equal amount of Rs.46,61,667.00 being the penalty and as such, total amount of Rs.93,23,334.00 was directed to be deposited by the petitioner within a period of 30 days from the date of passing of the impugned order.
(3.) The factual matrix of the case relevant for considering the questions raised are as follows:-