Statutory equity overrides contractual rigidity

The Court examined whether a Government undertaking could deny GST rate revision benefits by relying on contractual clauses despite a statutory amendment mandating equitable adjustment. 

It held that once the undertaking is an instrumentality of the State and governed by public works rules, the benefit of tax variation must be extended. 

Denial of such benefit, especially when granted by other State entities, was held to be discriminatory and violative of Article 14. The writ petition was held maintainable despite contractual dispute elements, and relief was granted in favour of the contractor.