service. It is incidental to employment and in excess of or in addition to the salary. It is an advantage or benefit given because of employment, which otherwise would not be available. 19. From this perspective, the employer’s grant of interest-free loans or loans at a concessional rate will certainly qualify as a ‘fringe benefit’ and ‘perquisite’, as understood through its natural usage in common parlance. 16 (1969) 2 WLR 775 (HL). 17 (1964) 1 WLR 650 (HL). 18 (2018) 15 SCC 670. Civil Appeal No. 7708 of 2014 & Ors. Page 10 of 1720. Two issues arise for consideration now: (I) Does Section 17(2)(viii) and/or Rule 3(7)(i) lead to a delegation of the ‘essential legislative function’ to the CBDT?; and (II) Is Rule 3(7)(i) arbitrary and violative of Article 14 of the Constitution insofar as it treats the PLR of SBI as the benchmark? I. Does Section 17(2)(viii) and/or Rule 3(7)(i) lead to a delegation of the ‘essential legislative function’ to the CBDT? 21. A Constitution Bench of Seven