On a writ petition by the assessee seeking to quash section 31 of the Finance Act, 2017 ((2017) 393 ITR (St.) 1) whereby sub-section (3A) has been inserted in section 71 of the 1961 Act to the effect that the assessee shall not be entitled to set-off of loss under the head “Income from house property” under section 56(2) to the extent the amount of the loss which exceeded two lakhs rupees against income under another head as being ultra vires the provisions of the Constitution of India or alternatively directing that sub-section (3A) to section 71 of the 1961 Act, is prospective in application and not applicable to the house loans raised prior to the amendment of the 1961 Act, i.e., prior to April 1, 2017 resulting in losses under the head “Income from house property dismissing the petition the Court held that, insertion of sub-section (3A) in section 71 in terms of section 31 d amendment not violative of article 14-Income-tax Act, 1961. The insertion of sub-section (3A) in section 71 of the 1961 Act was proportionate with the object sought to be achieved and not violative of article 19 of the Constitution. The alteration in the manner of imposing tax did not deprive the taxpayer from a benefit, rather it tantamounted to a realignment of the existing provisions bearing in mind the broader economic and policy considerations, which the Legislature was duly empowered to do. Amendment not violative of Article 14.