Rational tax classification upheld under Article 14 for plantation land taxed by use, not mere extent or productivity.

The Kerala Plantations (Additional Tax) Act, 1960 was upheld against an Article 14 challenge because the additional tax was levied on plantation land used for specified crops, not merely on land area or productivity. The statutory definition of plantation and the assessment method in Schedule II provided a rational basis for classification and aimed to avoid unequal tax incidence. In taxation, Article 14 is breached only if similarly situated property is subjected to unequal incidence without a rational basis. The Act did not create that defect, and the validity challenge failed.

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Issues: Whether the Kerala Plantations (Additional Tax) Act, 1960 was ultra vires Article 14 of the Constitution of India.

Analysis: The Act imposed additional tax not on the basis of the productivity or mere extent of land, but on the basis of its user as plantation land for specified crops. The statutory definition of plantation and the assessment machinery, including the method in Schedule II, showed a rational basis for classification and an attempt to avoid inequality in incidence of tax. In taxation matters, Article 14 is violated only where the same class of property similarly situated is subjected to unequal incidence without a rational basis. The Act did not suffer from that infirmity, and the Legislature was not bound to tax all possible categories merely because some were excluded.

Conclusion: The Act was not violative of Article 14 and the challenge to its validity failed.

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