Entertainment tax on video cassette exhibitions upheld as valid, with Article 14 challenge rejected on rational classification

Entertainment tax on video cassette recorder and video cassette player exhibitions under Section 6-A was upheld as constitutionally valid because entertainment through video equipment on admission fell within the charging provision. The Court accepted that the Legislature could use gross-collection or other presumptive collection methods, and treated the classification based on theatre nature and locality as a permissible legislative distinction. The scheme was also supported by an option for the proprietor and an assessment and payment machinery. The challenge under Article 14 failed, and the impugned rule challenge was not sustained except as specifically addressed in the judgment.

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Issues: Whether the levy of entertainment tax on video cassette recorder/video cassette player exhibitions under Section 6-A was constitutionally valid and whether the impugned rules were arbitrary or ultra vires under Article 14.

Analysis: The levy was upheld on the footing that entertainment by video equipment on admission fell within the charging provision and that the Legislature could adopt gross-collection or comparable presumptive methods for collection. The classification based on the nature of the theatre and the locality was treated as a permissible legislative classification, and the scheme allowed the proprietor an option and machinery for assessment and payment. The challenge based on unequal treatment and arbitrariness was rejected as the provisions were held to be supported by a rational nexus with the object of the tax law.

Conclusion: The constitutional challenge failed. Section 6-A was sustained and the levy was held valid; the impugned rule challenge did not succeed except to the extent specifically dealt with in the judgment.

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