draconian or harsh on the taxpayers. A complex problem has been solved through a straitjacket formula, meriting judicial acceptance. To hold otherwise, would lead to multiple problems/issues and override the legislative wisdom. The universal test in the present case is pragmatic, fair and just. Therefore, Rule 3(7) is held to be intra vires Article 14 of the Constitution of India. 35. We, accordingly, dismiss the appeals and uphold the impugned judgments of the High Courts of Madras and Madhya Pradesh. No order as to costs. ......................................J. (SANJIV KHANNA) ......................................J. (DIPANKAR DATTA) NEW DELHI; MAY 07, 2024. 28 Govt. of A.P. v. P. Laxmi Devi, (2008) 4 SCC 720. 29 Swiss Ribbons (P) Ltd. v. Union of India, (2019) 4 SCC 17. Civil Appeal No. 7708 of 2014 & Ors. Page 17 of 17