Article 14 challenge to a targeted tax concession failed where the policy favored units in a mini industrial estate.

A fiscal concession limited to industrial units located in a mini industrial estate and commencing after a specified date was upheld against an Article 14 challenge. The court treated the restriction as a policy choice aimed at encouraging small-scale industries in earmarked areas and held that such a classification is not invalid merely because another arrangement may seem fairer or more logical. Interference is justified only if the policy is patently arbitrary, discriminatory, or mala fide, and no such infirmity was shown. The challenge failed, and the denial of the tax concession was sustained.

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Issues: Whether the restriction of the tax concession to industrial units located within a mini industrial estate and commenced after a specified date violated Article 14 of the Constitution of India.

Analysis: The concession formed part of a governmental policy intended to encourage small-scale industries in earmarked areas. A policy choice of this nature is not liable to be struck down merely because another arrangement might appear fairer or more logical. Interference is warranted only where the policy is patently arbitrary, discriminatory, or mala fide. The restriction to units in the mini industrial estate, and to those started after the specified date, disclosed no such infirmity.

Conclusion: The challenge under Article 14 failed, and the denial of the tax concession was upheld.

Final Conclusion: The writ appeal was dismissed, leaving the governmental policy and the resulting denial of the concession undisturbed.

Ratio Decidendi: A court will not invalidate a fiscal policy choice granting a concession only to a defined class of beneficiaries unless the policy is shown to be patently arbitrary, discriminatory, or mala fide.

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