RANJIT SINGH vs THE COMMISSIONER OF INCOME-TAX, U. P. AND OTHERS.

The Supreme Court held that the proceedings against the petitioner for tax recovery were completed before the Constitution came into force, thus not subject to challenge under Article 14. The Court clarified that Section 8-A(2) of the Taxation on Income (Investigation Commission) Act, 1947, enforces settlement terms for income-tax that had escaped assessment. It determined that the petitioner was part of a special class of debtors who had evaded tax, and the classification was reasonable, upholding the recovery procedure as non-discriminatory.