3. In these two writ petitions filed under Article 226 and under Article 227 of the Constitution of India, M/s Jindal Refineries – petitioner has assailed the orders dated 24.01.2012 passed by the Revisional Authority in Stamp Revision No. 34 (2005-06) /1 (2011-12) and Stamp Revision No. 33 (2005-06) /1 (2011-12). Petitioner Company has been established under the Companies Act with an objective to process agricultural produce for preparation of oil. The petitioner company had purchased certain lands from different agriculturists and paid stamp duty thereon, as if, the purchase has been made for the agricultural purposes. The Sub Registrar, Kashipur, held a deficiency of stamp duty of Rs. 1,36,000/- and Rs. 95,940/- on the sale deeds. He sent a letter to the Collector for realizing the deficit stamp duty. Case bearing nos. 52/66 of 2003-04 and 52/67 of 2003-04 were registered. Having heard learned counsel for the parties and considering the material available on record, the Additional Collector (Revenue and Finance), Udham Singh Nagar came to the conclusion that there is no deficiency in stamp duty.