The contentions urged in support of the petitions admit of being noticed and formulated in the following terms: (a) The 'Act ', in its true nature and character, is not one imposing an 'Expenditure Tax ', as known to Law, accepted notions of Public Finance, and to legislative practice but is, in pith and substance, either a tax on Luxuries falling within Entry 62 of List II of the Seventh Schedule; or a tax on the consideration paid for the purchase of goods consti tuting an impost of the nature envisaged in entry 54 of List II, and clearly outside the legislative competence of the Union Parliament; (b) that even if the 'Act ' is held to impose a tax which is "sui generis" or a "non discript", tax with respect to which the Union Parliament is competent to make a law under Arti cle 248 and Entry 97 of List I, then, at all events, the 'Act ' is violative of Article 14 in as much as the differen tium on which the Hotels are classified is arbitrary and unintelligible has no rational nexus with the taxing policy under the 'Act '.