Reasonable tax classification upheld under Article 14 where body corporates were treated as a separate class with rational nexus.

A tax classification treating body corporates differently from other dealers was upheld as valid under Article 14 because body corporates were found to form an intelligible separate class with a distinct legal character. The Legislature was competent to impose a heavier burden on that class, and the notification issued under the Karnataka Sales Tax Act was held to have a rational nexus with the legislative object. The challenge based on non-arbitrariness therefore failed, and the impugned provisions and notification were not held ultra vires.

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Issues: Whether clause (xiii) of section 6-B(1) of the Karnataka Sales Tax Act, 1957 and the notification issued under section 8-A were violative of Article 14 of the Constitution of India for treating body corporates differently from other dealers.

Analysis: The challenged levy and notification were tested on the touchstone of equality and non-arbitrariness. The classification of body corporates was upheld as a separate class having a distinct legal character, and the Legislature was held competent to place a heavier tax burden on such class if it so chose. The differential treatment was found to rest on a rational basis and not to be unreasonable or arbitrary. The decision followed the principle of reasonable classification and rejected the contention that the notification lacked nexus with the object of the legislation.

Conclusion: The challenge under Article 14 failed, and the provisions and notification were not held ultra vires.

Final Conclusion: The writ petitions were liable to be rejected because the impugned tax classification and the consequential notification were constitutionally valid.

Ratio Decidendi: A tax classification is valid under Article 14 if the class identified is intelligible and the differential treatment has a rational nexus with the legislative object.

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