JUDGMENT Manish Mathur, J. Heard Shri S.M. Singh Royekwar, learned counsel for the petitioner and the learned State Counsel appearing for the opposite parties. 2. Petition under Article 226 of the Constitution of India has been filed challenging order dated 18.11.2006 passed under Section 47A of the Stamp Act, 1899 (for short 'the Act') whereby instrument of transfer dated 16.4.2003 has been found to be undervalued while finding property to be residential in nature although stamp duty as per agricultural rate has been deposited. Also under challenge is order dated 9.10.2007 rejecting recall application as well as order dated 11.8.2008 passed by revisional authority in Revision No.1 of 2007 under Section 56 of the Act. 3. Learned counsel for petitioner submits that perusal of impugned orders will make it evident that the same are completely non-speaking in nature and neither the objection filed by petitioner in proceeding under Section 47-A of the Act nor submissions in the memorandum of the revision have been considered by either of the authorities. It is submitted that in fact orders passed are clearly ex parte in nature and are based on an alleged spot inspection report, which also is against mandatory provisions of Rule 7(3)(c) of the U.P. Stamp (Valuation of Property) Rules, 1997 (for short 1997 Rules'), since no prior notice was ever given to petitioner before such spot inspection was ever conducted. Learned counsel for petitioner has placed reliance on the judgements rendered in the case of Ganga Ram v. State of U.P. and others, Misc. Single No.987 of 2010 decided on 7.2.2020 and Ram Khelawan @ Bachcha v. State of U.P. and another, 2005 SCC Online All 2247. 4. Learned State Counsel appearing for opposite parties has refuted submissions advanced by learned counsel for petitioner with the submission that when a doubt arose regarding valuation of land, spot inspection was done by the Assistant Sub Divisional Officer, Pratapgarh from which it could be ascertained that the property in question was residential and not agricultural and was, in fact, situated adjacent to the residential house of vendee. It is thus submitted that in view of situation of property in question, no error was committed by authorities in valuing the property as residential. 5. It is thus submitted that in view of situation of property in question, no error was committed by authorities in valuing the property as residential. 5. Upon consideration of submissions advanced by learned counsel for parties and perusal of material on record, it is evident that proceedings under Section 47-A of the Act were initiated against petitioner on report of Assistant Sub Divisional Officer, Pratapgarh in 2004 indicating the property in question to be residential in nature. The impugned order passed under Section 47-A of the Act is completely based on the aforesaid report. A perusal of aforesaid order also indicates that none of the submissions raised by petitioner in his objection have been adverted to by authorities concerned. The order, in fact, is quite non-speaking in nature and does not indicate any independent application of mind to the report submitted. 6. Same is situation with impugned order passed in revision under Section 56 of the Act, which, in fact, is even more taciturn in nature and does not even advert to the report and dismisses the revision only recording the fact that order passed under Section 47-A of the Act does not require any interference. None of the grounds taken by petitioner in memorandum of appeal have been adverted to. 7. Hon'ble the Supreme Court in the case of Assistant Commissioner, Commercial Tax Department, Works Contract and Leasing, Kota v. Shukla and others, (2010) 4 SCC 785 has clearly held that the reasons are the soul of an order from which the mind of authority passing the order can be discerned. The aforesaid principle is applicable not only to judicial but quasi judicial proceedings as well as in the present case where authorities are clearly exercising quasi judicial power in terms of the Act. The impugned orders having been passed without adverting to submissions raised by petitioner in his objection as well as in the memorandum of appeal are clearly non-speaking in nature and do not indicate any independent application of mind particularly since no reason whatsoever has been recorded therein. 8. Apart from the above, this Court in the case of Ganga Ram (supra) has clearly held that provision of Rule 7 of 1997 Rules are mandatory in nature, the violation of which vitiates orders passed under the Act. Relevant paragraphs nos.25 and 26 of judgement is extracted below: - "25. 8. Apart from the above, this Court in the case of Ganga Ram (supra) has clearly held that provision of Rule 7 of 1997 Rules are mandatory in nature, the violation of which vitiates orders passed under the Act. Relevant paragraphs nos.25 and 26 of judgement is extracted below: - "25. Under the U.P. Stamp Valuation of Property Rules, 1997, Rule-7 provides the procedure on receipt of a Reference or when suo motu action is proposed under Section 47-A of the Act. Rule 7(2)(c) provides that the Collector may inspect the property after due notice to parties to the instrument. 26. The complete reading of the aforesaid Rule clearly indicates that while deciding the proceedings under Section 47-A of the Act, the Collector or any other officer authorized to determine stamp duty, is required to make an inspection after due notice to the parties to the instrument. The proceedings under Section 47-A of the Act shall not be decided merely placing reliance on the ex-parte report of the Sub Registrar or the Tehsildar for that purpose." 9. In the present case, it is evident that the alleged spot inspection does not indicate any prior notice having been given to the petitioner in terms of Rule 7 of 1997 Rules. 10. Another co-ordinate Bench of this Court in Ram Khelawan (supra) has also held that order passed under Section 47 of the Act cannot be based only on spot inspection report and situation of property in question is required to be seen on the basis of exemplar as well. The aforesaid dictum of this Court has also not been adhered to while passing the orders. 11. In view of the aforesaid facts and circumstances, it is evident that impugned orders dated 18.11.2006 passed under Section 47A of the Stamp Act, 1899 and order dated 9.10.2007 rejecting the recall application as well as order dated 11.8.2008 passed by revisional authority in Revision No.1 of 2007 being clearly erroneous in nature are quashed by issuing a writ in the nature of certiorari. 12. Learned counsel for the petitioner submits that in pursuance of the impugned orders and direction of this Court certain amount was deposited by petitioner before the authority concerned. Liberty is granted to petitioner to file an application seeking refund of the said amount. 12. Learned counsel for the petitioner submits that in pursuance of the impugned orders and direction of this Court certain amount was deposited by petitioner before the authority concerned. Liberty is granted to petitioner to file an application seeking refund of the said amount. In case such an application is filed, the authority concerned is directed to refund the deposited amount along with interest @ 6% per annum within a period of three months from the date the application is received. Petitioner shall also be entitled to the aforesaid interest including the date of deposit and the date on which the payment was made. 13. Resultantly, the petition succeeds and is allowed. Parties to bear their own costs.