Dismissing the petition the Court held that the terms and conditions of employment vary significantly as between employees of the Central Government and those of public sector undertakings and, even as between different public sector undertakings. Therefore, these classes of employees do not constitute a single homogeneous class. Consequently, the contention that employees of public sector undertakings, should be treated in the same manner as regards gratuity as the employees of the Central Government is not tenable. Court held that when there was no ambiguity either in section 10(10)(ii) of the Income-tax Act, as it stood as on the date of retirement of the assessee, or in the amendment Notification S. O. 1213(E), the applicable exemption limit could not be raised by an order of court to Rs. 20 lakhs as regards the assessee. The assessee had not made out a case that the amendments should be implemented with retrospective effect from January 1, 2016.