Promissory estoppel and sales tax exemption failed where the Court refused to compel a further statutory notification.

Promissory estoppel did not justify a mandamus requiring the State to issue a further notification under section 6 of the Orissa Sales Tax Act to extend sales tax exemption to cement. The existing notification under section 7 was treated as reflecting the promises in the Industrial Policy Resolution, and the Court held it could not enlarge the scope of that promise or compel the State to make a new one on the petitioners' understanding. Relief was therefore misconceived, though the petitioners remained free to challenge the assessment orders on their own merits.

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Issues: Whether the petitioners were entitled, on the basis of promissory estoppel and the Industrial Policy Resolution, to a writ directing the State to issue a notification under section 6 of the Orissa Sales Tax Act, 1947 extending sales tax exemption to cement.

Analysis: The notification already issued under section 7 of the Orissa Sales Tax Act, 1947 was held to reflect the promises contained in the Industrial Policy Resolution. The requested relief would have required the Court to enlarge the scope of the alleged promise and to direct the State to make a further promise consistent with the petitioners' understanding, which was not permissible. The assessing authority could not grant relief in anticipation of a prospective notification, and the claim for a direction to issue a section 6 notification was found to be misconceived. The Court also clarified that it had not scrutinised the assessment orders, leaving the petitioners free to challenge them on their own merits.

Conclusion: The petitioners were not entitled to a mandamus directing issuance of a section 6 notification, and the plea based on promissory estoppel failed.

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