The appellant is a Charitable Trust registered under the provisions of the Bombay Public Trust Act, 1950. On 27.09.2014, the appellant filed an application under S.35AC of the Act  to the National Committee for Promotion of Social and Economic Welfare, Department of Revenue, North Block, New Delhi  for grant of approval to their hospital project as specified in S. 35AC of the Act so as to enable any “assessee” to incur expenditure by way of making payment of any amount to the appellant for construction of their approved hospital project and accordingly claim appropriate deduction of such payment from his total income during the previous year. Like the appellant, several persons, as specified in Section 35AC of the Act, also made applications to the Committee for grant of approval to their hospital projects.  A notification was issued by the Government of India on 07.12.2015 mentioning therein that the Committee has approved 28 projects as “eligible projects” under Section 35AC of the Act. The name of the appellant appears at serial No. 10 in the notification dated 07.12.2015. . The appellant, received amount by way of donation from several assesses.  However due to insertion of S. 35AC(7)  from the assessment year 2018­-19 by the Finance Act, 2016 with effect from 01.04.2017 the benefit of the exemption was withdrawn . The appellant challenged the validity of the provision S. 35AC(7) with effect from 1-4 2017 .. High Court dismissed the petition holding that the provision is valid in law .On appeal to supreme Court the Court held that aplea of promissory estoppel is not available to an assessee against the exercise of legislative power nor any vested right accrues to an assessee in the matter of grant of any tax concession to him. In a taxing statute, a plea based on equity or/and hardship is not legally sustainable. Accordingly the withdrawal of exemption is valid and dismissed the petition.(CAC No. 5849 of 2019, dt. 25.07.2019)