The TPA Conundrum: Is the 'Owner-Occupier' Exemption Constitutional?

The Transplantation of Properties Act, 1882, in Section 6(1) provides an exemption to the owner-occupier from transfer tax. But does this exemption infringe on Article 14 of the Indian Constitution, which guarantees equality before the law? The 'owner-occupier' definition is ambiguous and has been interpreted in various ways by different courts. If we consider the owner-occupier as a mere taxpayer, it's hard to justify the exemption, as it unfairly favors a specific class of people. On the other hand, if we view it as a matter of property rights, then the exemption could be seen as a necessary protection of the owner's property interests. So, my question to you all: do you think the 'owner-occupier' exemption is constitutional?