Reliance was placed in support of this position on the following passage from the judgment of Mahajan, C. J. in Shree Meenakshi Mills ' case, 157 1244 supra, at pages 795 796: "Assuming that evasion of tax to a substantial amount could form a basis of classification at all for imposing a drastic procedure on that class, the inclusion of only such of them whose cases had been referred before 1st September, 1948, into a class for being dealt with by the drastic procedure, leaving other tax evaders to be dealt with under the ordinary law will be a clear discrimination for the reference of the case within a particular time has no special or rational nexus with the necessity for drastic procedure. . " These observations were made to repel the first argument of the learned Attorney General that the class of substantial evaders who fall within section 5(1) were only those whose cases had been referred within the date fixed.