https://www.taxtmi.com/caselaws?id=214615 The HC held that the retrospective insertion of conditions in the provisos to Section 80HHC(3) discriminating between assessees with finalized assessments and those with pending assessments violates Article 14 due to lack of rational nexus and arbitrariness. The Revenue failed to justify this classification. While the doctrine of promissory estoppel does not bind the Legislature, individual assessees may invoke it if adversely affected. The Court ruled that substantive amendments with retrospective effect are impermissible when the relevant scheme has expired. Consequently, the amendment was quashed to the extent it applied retrospectively to prior assessment years for assessees with export turnover exceeding Rs. 10 Crore, allowing the amendment's operation only prospectively to prevent detriment to any assessee. en-us Mon, 02 Jul 2012 00:00:00 +0530 Thu, 14 Aug 2025 11:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=214615 The HC held that the retrospective insertion of conditions in the provisos to Section 80HHC(3) discriminating between assessees with finalized assessments and those with pending assessments violates Article 14 due to lack of rational nexus and arbitrariness. The Revenue failed to justify this classification. While the doctrine of promissory estoppel does not bind the Legislature, individual assessees may invoke it if adversely affected. The Court ruled that substantive amendments with retrospective effect are impermissible when the relevant scheme has expired. Consequently, the amendment was quashed to the extent it applied retrospectively to prior assessment years for assessees with export turnover exceeding Rs. 10 Crore, allowing the amendment's operation only prospectively to prevent detriment to any assessee. Case-Laws Income Tax Mon, 02 Jul 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=214615