Reasonable classification upheld for professional account-keeping rules; section 44AA survived the Article 14 challenge.

Section 44AA of the Income-tax Act was upheld against an Article 14 challenge because the distinction between enumerated professions and other occupations was treated as a reasonable classification. Advocates, chartered accountants, doctors and engineers were regarded as a separate class due to statutory regulation and heavier record-keeping obligations, while occupations such as street vendors and hawkers were not similarly situated. The monetary threshold for non-enumerated professions was accepted as a practical basis for requiring accounts. The later insertion of rule 6F extended a similar financial limit to the covered professions and removed any residual discrimination. The constitutional challenge therefore failed.

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Issues: Whether section 44AA of the Income-tax Act, 1961 was constitutionally invalid as violating article 14 of the Constitution of India by treating enumerated professions differently from other professions, and whether the later insertion of rule 6F removed any alleged discrimination.

Analysis: The classification between enumerated professions and other professions was upheld as a reasonable one. Professions such as advocates, chartered accountants, doctors and engineers were treated as a distinct class because they are generally regulated by statute and carry greater obligations to maintain accounts, whereas occupations like street vendors and hawkers were not similarly situated. The monetary threshold for those outside the enumerated class was found to be a practical basis for requiring maintenance of accounts. The court also noted that the insertion of rule 6F extended a similar financial limit to the professions covered by section 44AA(1), thereby removing any residual complaint of discrimination.

Conclusion: The challenge to section 44AA failed and the provision was held not to offend article 14.

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