The petitioner filed the writ petition on the ground that the amendment is discriminatory and also prospective in nature. The Court held that though there are different class of assessees under the Act, they cannot be considered to be equal, merely for reason of their being assessed under that Act. The amendment is valid. The Court also held that  it was expressly stated that the amendment would be effective from April 1, 2018. There is a presumption against the retrospective operation of a statute and further a statute is not to be construed to have a greater retrospective operation than that expressed in the language. It cannot be related back to the date of enactment of the original provisions, as an amendment supplying a remedial effect. Section 2(47)(v) read with sections 45 and 48 remains as such, applicable to all assessees who transferred a capital asset coming within the definition of section 53A of the Transfer of Property Act, except those individuals and Hindu undivided families, who by virtue of a joint development agreement transferred the capital assets after April 1, 2018.