While interpreting the section 254(2A) of the Act, third proviso,  wherein the section provided  automatic vacation of stay  on completion of 365 days. The Court held that challenges to tax statutes made under article 14 of the Constitution of India can be on grounds relatable to discrimination as well as grounds relating to manifest arbitrariness.  These grounds may be procedural or substantive in nature. The expression permissible policy taxation would refer to a policy that is constitutionally permissible. If the policy is itself arbitrary and discriminatory, such policy will have to be struck down. Referred  Suraj Mall Mohta and Co v. A.V Visvanathan Sastri  (1955) 1 SCR 448,  Kunnathat Thatehunni Moorrpi Nair v. State of Kerala (1961) 3 SCR 77  (5-Judge decision), UOI v. A.Sanyasi Rao (1996) 3 SCC 465,  Shyayara Bano v.UOI (2017) 9 SCC 1 (5-Judge decision) (5-Judge decision),   State  of M.P v. Bhopal Sugar Industries Ltd (1964) 52 ITR 443 (SC)