Promissory estoppel preserves promised sales tax incentives where industry relied on clear government resolutions and no overriding public interest was shown.

A State may be bound by promissory estoppel where it has made a clear, published promise of fiscal incentive, the industrial unit has acted on that assurance by altering its position, and no overriding public interest justifies withdrawal. The commentary states that repeated government resolutions promised ten years' sales tax incentive to new large and medium industries, and that a later statutory notification granting only five years could not defeat the earlier promise. The stated effect is that the promised benefit remained enforceable, and the contrary exemption order was unsustainable.

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Issues: Whether the industrial unit was entitled to sales tax exemption for ten years from the date of production on the basis of the State Government's resolutions, notwithstanding the shorter exemption period under the statutory notifications.

Analysis: The State Government had repeatedly published resolutions promising incentives to new large and medium industries, including exemption from sales tax on raw materials for ten years from commencement of production. The unit acted on those representations, altered its position by setting up the industry, and the subsequent departmental communication during the pendency of the writ also affirmed entitlement under the resolutions. The statutory notifications provided only a five-year exemption, but the Court held that the Government could not defeat the earlier solemn promise merely by relying on the notifications. Applying the principle of promissory estoppel, and finding no sufficient public interest justifying withdrawal of the promised benefit, the Court concluded that equity favoured the petitioner.

Conclusion: The petitioner was entitled to sales tax incentives for ten years under the Government's resolutions, and the contrary order limiting exemption to 31 March 1979 could not stand.

Final Conclusion: The writ petition succeeded, the impugned exemption order was set aside, and the industrial unit's entitlement to the promised sales tax incentives was upheld.

Ratio Decidendi: Where a State makes a clear and published promise of fiscal incentive, induces action in reliance on it, and no overriding public interest is shown, the State is bound by promissory estoppel and cannot deny the promised benefit by resorting to a contrary statutory notification.

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