The assessee is  incorporated on 7-9-2007, which established its unit on May, 2012, at Kandla Special Economic Zone, Gujarat, for manufacture of specialized refractories and commenced operations from May, 2012. It  became eligible for claiming exemption under section 10AA, from the assessment year 2013-14 onwards.On 1-4-2018, an Explanation was inserted after section 10AA(1) by the Finance Act, 2017, with effect from the aforesaid date prospectively. On writ, the assessee contested the Explanation to section 10AA(1) inserted by the Finance Act, 2017 with prospective effect, as unconstitutional and allegedly violative of articles 14, 19(1)(g), and 265 of the Constitution of India. Court held that  explanation after sub-section (1) of section 10AA, inserted by amendment with prospective from 1-4-2018, applicable in respect of the assessment year 2018-19 and subsequent years is constitutional and is a valid piece of legislation and is not arbitrary, discriminatory and is not violative of articles 14, 19 & 265 of the Constitution of India.  Circulars & Notifications : Circular No. 3 of 2008, dated 12-3-2008.