Sales tax exemption requires a specific scheme; a statutory reference to incentives does not create a perpetual exemption.

Section 11(b) of the Haryana Regulation and Control of Crusher Act, 1991 does not confer an absolute or perpetual sales tax exemption; it only refers to incentives, including exemption or deferment, as made available under the Industries Department's incentive schemes. The applicable policy placed certain stone crushers in the negative list, and no specific scheme or notification was shown to grant licensed stone crushers an automatic exemption. The negative list under the Haryana General Sales Tax Rules, 1975 therefore continued to govern entitlement, and later notifications did not create a vested right. On that basis, promissory estoppel and implied repeal were inapplicable.

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Issues: Whether stone crushers holding a licence under the Haryana Regulation and Control of Crusher Act, 1991 were entitled to sales tax exemption under section 11 of that Act and the Industries Department policy, and whether the impugned notifications and rejection order were barred by promissory estoppel or implied repeal.

Analysis: Section 11(b) of the 1991 Act did not grant an absolute or perpetual exemption from sales tax. It only referred to incentives, including exemption or deferment of sales tax, as admissible under the incentive schemes of the Industries Department of the State Government. The material placed before the Court showed that the applicable policy placed stone crushers not holding a licence under the 1991 Act in the negative list, and there was no specific scheme or clause showing that licensed stone crushers were automatically exempt from sales tax. The Court further held that the negative list under the Haryana General Sales Tax Rules, 1975 continued to govern entitlement, and the later notifications did not create a vested right in the petitioner. Since no specific exemption to licensed stone crushers was established, the doctrines of promissory estoppel and implied repeal had no application.

Conclusion: The petitioner was not entitled to sales tax exemption, and the challenge to the notifications and rejection order failed.

Ratio Decidendi: A reference in a special statute to sales tax incentives under departmental schemes does not by itself confer a direct or perpetual exemption unless a specific scheme or notification grants that benefit; where the governing policy places the unit in the negative list, no enforceable exemption arises and estoppel cannot override the statutory scheme.

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