Reasonable classification under Article 14 failed where tax exemption notification revived profit motive and remuneration distinctions.

Article 14 permits reasonable classification only where there is an intelligible differentia with a rational nexus to the statute's object. Applied to exemption from entertainment tax under the Bengal Amusement Tax Act, 1922, the statutory criterion after amendment was whether the entertainment served a social, educational or scientific purpose. A notification that further divided group theatre, amateur theatre or amateur jatra from professional theatre by reviving considerations of profit motive and artist remuneration was held to have no rational connection with that object. The notification was therefore unconstitutional and unenforceable, and the assessee's challenge succeeded.

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Issues: Whether the notification issued under Section 8 of the Bengal Amusement Tax Act, 1922, creating a distinction between group theatre, amateur theatre or amateur jatra and professional theatre for exemption from entertainment tax, was discriminatory and violative of Article 14 of the Constitution of India.

Analysis: The governing principle under Article 14 permits reasonable classification only if it is founded on an intelligible differentia and that differentia has a rational relation to the object of the statute. After the amendment of Section 8, the statutory criterion for exemption was social, educational or scientific purpose. The substituted provision did not retain the earlier emphasis on profit motive or the mode of remuneration of artists. The notification, by reintroducing those excluded considerations through executive classification, created a further subdivision among entertainments which all shared the same social character. Such classification had no rational nexus with the object of the Act and could not be justified by the doctrine of permissible micro-classification.

Conclusion: The notification was held to be unconstitutional and unenforceable, and the challenge to it succeeded in favour of the assessee.

Ratio Decidendi: Where the statute itself confines exemption to entertainments serving social, educational or scientific purposes, the executive cannot create an additional classification based on profit motive or remuneration structure unless that classification satisfies the test of intelligible differentia and rational nexus.

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