The petitioner filed the writ petition challenging the provisions of section 80IBA  of the Act enacted vide Finance  Act, 2016 to provide a tax holiday to the real estate developers and the provisions of section 80IAC of the Act The provisions of section 80-IBA of the Income-tax Act, 1961, was enacted by the Finance Act, 2016 to provide a tax holiday to real estate developers. The provisions of section 80-IAC of the Act were also enacted under the Finance Act, 2016 providing incentives to start-up companies for availing of deductions provided they were set up on or after October 1, 2019 and had commenced operations. On a writ petition parity was claimed with persons given the benefit of the provisions of section 80-IAC of the Act, and the claim was that non-extension of the timelines of eligibility beyond March 31, 2022, operated as a discrimination against the assessees who were real estate developers. Dismissing the writ petition the Court held that the petition was grossly lacking in sufficient pleadings required for making out a case of discrimination as claimed by the assessee. The petition lacked all material particulars required to be stated in the pleadings, to draw some parity or similarity between members of the assessee and persons stated to be covered by the provisions of section 80-IAC of the Act. The provision was valid and the timelines prescribed under it could not be extended. Referred  V. S. Rice and Oil Mills v. State of A. P. [1964] AIR 1964 SC 1781