Prashanti Medical Services & Research Foundation vs The Union Of India & Ors.

Whether the insertion of sub-section (7) in Section 35AC of the Income Tax Act, 1961, by the Finance Act, 2016, which disallows deductions from the assessment year 2018-19 onwards, applies retrospectively to projects approved prior to its insertion, thereby affecting the appellant charitable trust's ability to receive donations for its hospital project for the third financial year (2017-18) of its three-year approval period --- Held: No. The provision is prospective, and the appellant's donors were rightly allowed deductions for the first two years (2015-16 and 2016-17) but not for the third year (2017-18). The constitutional validity of sub-section (7) is upheld, and the plea of promissory estoppel against legislative power is not sustainable.