13 . Mr. Mishra, learned ASC referring to the observation of this Court in W.P.(C) No.8942 of 2021 as well as averments of counter affidavit, submits that direction in the said writ petition was with regard to lease-cum-sale deed to be produced subsequent to the said order. Thus, no application for refund of stamp duty in respect of registration of the lease-cum-sale deed, which was registered prior to the decision of this Court in W.P.(C) No.8942 of 2021, should be entertained. It is his submission that in view of the decision in W.P.(C) No.8942 of 2021, many application for refund of stamp duty of Lease-cumSale deeds registered in the year 1998 onwards have been filed and are pending before IGR. If the interpretation made by Miss Mahapatra, learned counsel for the Petitioner, is accepted, it will be difficult on the part of the State Government to refund the said amount. Since the impugned order was passed in compliance of the direction made in W.P.(C) No.12990 of 2022, which was passed in the light of the order passed in W.P.(C) No.8942 of 2021, the IGR has committed no error in rejecting the application of the Petitioner for which the writ petition is liable to be dismissed. In view of the direction of this Court in W.P.(C) No.8942 of 2021, Board of Revenue has issued the Circular No.5921 dated 1st December, 2021 instructing all Registering Officers of the State to apply the principle settled in the said order of this Court to all transactions subsequent to the said order. In the instant case, the transaction in question was made much before issuance of the aforesaid instruction. Thus, the same may not be applied retrospectively extending the benefit of refund of stamp duty to the Petitioner.
