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    <title>2020 (12) TMI 134 - MADRAS HIGH COURT</title>
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    <description>Gratuity tax exemption under section 10(10)(ii) was examined in relation to the enhanced ceiling under the Payment of Gratuity Act. The Court noted that the higher limit of Rs. 20 lakhs took effect only from 29.03.2018, and the corresponding income-tax notification applied that benefit only to employees retiring or becoming entitled on or after that date; retrospective extension from 01.01.2016 was rejected. The challenge to the appointed date as discriminatory also failed because Central Government employees and PSU employees were not treated as a single homogeneous class, and an expressly fixed effective date could not be rewritten. Exemption notifications were held to require strict construction, with ambiguity operating in favour of the Revenue.</description>
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      <description>Gratuity tax exemption under section 10(10)(ii) was examined in relation to the enhanced ceiling under the Payment of Gratuity Act. The Court noted that the higher limit of Rs. 20 lakhs took effect only from 29.03.2018, and the corresponding income-tax notification applied that benefit only to employees retiring or becoming entitled on or after that date; retrospective extension from 01.01.2016 was rejected. The challenge to the appointed date as discriminatory also failed because Central Government employees and PSU employees were not treated as a single homogeneous class, and an expressly fixed effective date could not be rewritten. Exemption notifications were held to require strict construction, with ambiguity operating in favour of the Revenue.</description>
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