Retrospective statutory ceiling defeats promissory estoppel claim for interest-free sales tax loan benefits.

Section 3 of the Andhra Pradesh Interest-free Sales Tax Loans for Industries (Imposition of Ceiling) Act, 1987 was held to apply retrospectively from 1 January 1976, so the Rs. 10 lakh ceiling formed part of the incentive scheme under G.O. Ms. No. 224. G.O. Ms. No. 483 was treated as only quantifying the benefit under the earlier scheme, not creating an independent entitlement. Promissory estoppel could not be used to enforce a promise inconsistent with the retrospective statute, and the earlier constitutional challenge had already been rejected. The demand notices were therefore upheld and relief for implementation of G.O. Ms. No. 483 was refused.

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Issues: Whether section 3 of the Andhra Pradesh Interest-free Sales Tax Loans for Industries (Imposition of Ceiling) Act, 1987 applied to the petitioner's claim for interest-free sales tax loan and barred enforcement of G.O. Ms. No. 483 dated 9 September 1986 on the basis of promissory estoppel.

Analysis: The ceiling imposed by section 3 was given retrospective effect from 1 January 1976 and therefore operated as if the limitation of Rs. 10 lakhs had always formed part of the incentive scheme under G.O. Ms. No. 224. G.O. Ms. No. 483 was treated as quantifying and settling the benefit traceable to the earlier Government order rather than conferring an independent or additional entitlement outside that scheme. Since promissory estoppel cannot override a legislative mandate, the petitioner could not compel implementation of a promise inconsistent with the retrospective statute. The constitutional challenge had already been rejected in earlier binding authority and the retrospective ceiling was upheld as a valid legislative measure in public interest.

Conclusion: Section 3 applied to the petitioner's case, promissory estoppel could not be invoked against the statute, and the demand notices were held valid; the relief sought for implementation of G.O. Ms. No. 483 was refused.

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