The asseessee challenged the constitutional validity of Sub-S. (3A) of S. 71 only aims at capping the set off of losses under the head of “Income from house property” from any other head of income at Rs. 2 lakh is violative of Article 14 and 19(1)(g) of the Constitution of India.  Dismissing the petition the Court held that. Court held that  neither the old provisions, as they existed, nor the amended provisions endeavour to create or disturb any indefeasible right in favour of the assessee so as to allow him to claim any legitimate expectation to set off the amount in the manner canvassed by him. In the absence of any such crystallized right, the argument of the assessee that the concerned amendment is violative of Art. 14 of the Constitution does not hold any water. Additionally, the insertion of sub-S. (3A) does not take away the benefits of deduction provided to the assessee in toto, rather it only attempts to circumscribe the indefinite amount of set off to a certain amount. Impugned provision does not create an absolute restriction on the taxpayer’s pre-existing right to claim the deduction in question and the capping of Rs. 2 lakh is meant to prevent the abuse of the relevant provision. Tool adopted to prevent this abuse is also reasonable and it is not the case of the assessee that the legislature had a less restrictive tool to achieve the object. Therefore, the  law is proportionate with the object sought to be achieved and cannot be faulted for being violative of Art. 19. Further, it is vividly discernible from a plain reading of the amended provision that the said amendment came into effect only from 1st April, 2018 i.e., period commencing after the passing of the Act of 2017.