Petitioners were associations of officers of nationalised banks. They challenged amendments to section 17(2)(ii) by Finance Act, 2007  on the ground that  amendments created a legal fiction based on which it could now be presumed that employees allotted bank-owned accommodation were deemed to have received a concession in matter of rent respecting such accommodation and amendments broadly measured value of such concession as difference between specified percentage of employee’s salary and rent recoverable or payable by such employees. Petitioners contended that the  amendments were arbitrary, discriminatory and, therefore, violative of article 14 of Constitution of India. Dismissing the petition the Court held that the  amendments to section 17(2)(ii) do not create any taxing liability or amend charging provisions and they only provide machinery for assessing and recovering tax on concession in rent for accommodation provided by employer to employee.  Merely  because bank employees drawing higher salaries are called upon to bear a proportionately higher burden, it does not mean that there is any hostile discrimination within class or any manifest arbitrariness involved in the  amendments. Amendments were a time-tested and permissible legislative exercise and they did not violate any constitutional provisions and thus, could not be held to be unconstitutional, ultra-vires, or null and void.