Dismissing the petition the Court held that , a provision can be held unconstitutional only when the Legislature was incompetent to bring out the legislation or it offends some provision of the Constitution or when it is manifestly arbitrary. Parliament is competent to pass legislation on taxes on income under entry 82 of List I of the Seventh Schedule to the Constitution. Section 234F of the Income-tax Act, 1961 is not violative of any of the other provisions of the Act or the Constitution of India. The classification of all such defaulters as one class is a reasonable classification and does not offend article 14 of the Constitution of India.