Single Judge while dealing with a challenge to constitutional validity of section 206AA read down section 206AA and held that it is inapplicable to persons whose income is below taxable limit. On appeal by the revenue the Court held that it is trite law that constitutional validity of provision has to be tested on grounds of legislative competence and violation of fundamental rights.  Whether hardship or equity is not relevant in interpreting provisions relating to taxation. Principle of reading down a provision can be applied for limited purpose of making a particular provision workable and to bring it in harmony with other provisions of statute and has to be used keeping in view scheme of Act and to fulfil its purposes.  Court held that Single Judge had neither recorded a finding that parliament does not have legislative competence to enact section 206AA nor had recorded a finding that aforesaid provision was violative of fundamental rights, it could not have applied principle of reading down merely on basis of hardship or equity. Therefore, conclusion recorded by Single Judge that section 206AA would not be applicable to persons whose income is below taxable limit could not be upheld. Order of single judge was quashed. Followed Calcutta Guj. Society v. Calcutta Municipal Corporation (2003) 10 SCC 533.