Manufacturers denied tax benefits due to lack of clear promise in government notification.

The Court dismissed both Civil Appeal No. 951 of 1976 and Civil Appeal No. 1011 of 1977, ruling that the appellants, manufacturers of edible oil, were not entitled to tax benefits claimed under a government notification. The Court found that the notifications did not contain unalterable promises or specific references to industries, emphasizing the need for a clear promise by the government causing detrimental reliance to apply promissory estoppel in fiscal legislation. The appellants failed to prove such a promise, resulting in the dismissal of their appeals.

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Issues:
1. Interpretation of notification granting exemption from sales tax to new industries.
2. Application of the doctrine of promissory estoppel in fiscal legislation.
3. Claim of estoppel based on government assurances regarding tax benefits for new industries.

Civil Appeal No. 951 of 1976:
In this case, the appellants, manufacturers of edible oil, claimed exemption from sales tax based on a notification issued by the State Government. The appellants argued that assurances by government officials and a notification entitled them to tax benefits for a period of five years. However, the Court found that the notification did not contain any promise of unalterable benefits or reference to specific industries. The Court noted that the government had the authority to modify industrial policies and fiscal benefits. The appellants failed to establish a factual basis for promissory estoppel as they did not prove any definite promise made by the government that led to their detriment. The Court dismissed the appeal, stating that the appellants were not entitled to the tax benefits claimed.

Civil Appeal No. 1011 of 1977:
Similar to the previous case, the appellant in this appeal set up a factory relying on a government notification granting tax benefits to new industries. The appellant argued for promissory estoppel based on their investment and the timing of setting up the factory. However, the Court found that the appellant failed to establish a clear promise by the government that caused detriment to the appellant. The Court noted that the factual basis for promissory estoppel was lacking, and the appellant could not prove that the subsequent notification withdrawing benefits caused prejudice. Consequently, the Court dismissed the appeal, stating that no costs were to be awarded.

In both cases, the Court emphasized the importance of proving a clear promise by the government leading to detrimental reliance for the application of promissory estoppel in fiscal legislation. The Court held that mere reliance on government assurances without concrete evidence of a promise and resulting prejudice was insufficient to claim estoppel in tax matters.

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