Prashanti Medical Service & Research Foundation v. UOI ( 2019) 416 ITR 485/ 180 DTR 209/ 309 CTR 457 / 265 Taxman 504 (SC), www.itatonline.org

Interpretation of taxing statutes – Equity or hardship not factor to be considered in deciding validity of provision- Promissory estoppel- No estoppel against legislature . [ S.35AC, Art .142 ]

Court held that in a taxing statute , a plea based on equity or hardship is not legally sustainable . The validity of any provision especially a taxing provision cannot be struck down on such reasoning . The plea of promissory estoppel is not available to an assessee against the excise  of legislative power. No vested right accrues to an assessee in the matter of grant of any tax concession to him .