Classification of persons

Legislature is competent to classify persons or properties into different categories subject to different rates of taxes

If same class of person is subjected to an incidence of taxation, resulting in inequality amongst them, is liable to be struck down on account of infringement of Fundamental Right of equality

Neither discrimination can be pleaded in fiscal statutes nor such statute can be struck down at the touchstone of Art. 25 of the Constitution

Equal protection of law does not envisage that every citizen is treated alike in all circumstances but it contemplates that persons similarly situated or similarly placed are to be treated alike.