The issue at hand pertains to the taxation of concessional interest rates on bank loans to employees with the All India Bank Officers Confederation contesting the legitimacy of Section viii ... of the Income Tax Act and Rule i of the Income Tax Rules asserting that such classification constitutes arbitrary excessive delegation of legislative authority in response various bank staff unions and officers associations initiated writ petitions in the High Courts of Madras and Madhya Pradesh to nullify Rule i on grounds of unconstitutionality and improper benchmarking against SBI s PLR rather than actual rates which were ultimately dismissed affirming Rule i 's constitutional validity prompting an appeal to the Supreme Court of India