Promissory estoppel and purchase tax exemption depend on the actual government representation, not an expanded reading of policy.

Government incentive resolutions will support promissory estoppel only to the extent of the representation actually made and relied upon. Reading the Gujarat Sales Tax Act, 1969 schemes, the exemption notifications under section 49, and the policy history together, the article states that the promised purchase tax exemption for eligible new industrial units extended only to tax payable under section 15. No representation was made for exemption from purchase tax under section 18 on raw materials such as sugarcane, and no change of position on that basis was shown. The result is that the exemption cannot be enlarged beyond the clear scope of the statutory scheme.

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Issues: Whether the Government resolutions dated 22 December 1977 and 27 August 1980 represented that eligible new industrial units would be entitled to exemption from purchase tax on raw materials, including sugarcane, under section 18 of the Gujarat Sales Tax Act, 1969, so as to attract promissory estoppel.

Analysis: The incentive policy was traced through the earlier and later resolutions and the exemption notifications issued under section 49 of the Gujarat Sales Tax Act, 1969. Reading the schemes as a whole, the Court found that the representation made by the Government was only that purchase tax exemption would be available in relation to tax payable under section 15 of the Gujarat Sales Tax Act, 1969. The policy history, the wording of the notifications, and the consistent administrative practice showed that no promise was held out for exemption from purchase tax under section 18. The petitioners also had not altered their position on the basis of any such representation.

Conclusion: The claim based on promissory estoppel failed, and the petitioners were not entitled to exemption from purchase tax under section 18 of the Gujarat Sales Tax Act, 1969.

Final Conclusion: The incentive resolutions did not extend purchase tax exemption on sugarcane purchases beyond the statutory scheme implemented under section 15, so the writ petitions could not succeed.

Ratio Decidendi: A policy resolution will support promissory estoppel only to the extent of the representation actually made and acted upon, and a purchase tax exemption cannot be enlarged beyond the clear scope of the scheme and the exemption notifications issued under the governing statute.

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