Promissory estoppel barred withholding the eligibility certificate after State approval under the sales tax exemption notification.

An exemption notification issued under section 12 of the Madhya Pradesh General Sales Tax Act, 1958 had the force of law and could not be cut down by executive instructions. Where the petitioner had satisfied the prescribed conditions and the State Level Committee had approved grant of the eligibility certificate, the State was bound by that commitment and could not refuse to act on it without a legally sustainable reason. The doctrine of promissory estoppel and the principle of substantive legitimate expectation also barred the State from resiling from its unequivocal representation. On that basis, the eligibility certificate could not be withheld and was required to be issued.

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Issues: Whether the respondents could withhold the eligibility certificate for pioneer-industry sales tax exemption after approval by the State Level Committee and communication of that decision.

Analysis: The exemption notification issued under section 12 of the Madhya Pradesh General Sales Tax Act, 1958 had the force of law and could not be curtailed by executive instructions. Once the petitioner satisfied the stated conditions and the State Level Committee had approved the grant of eligibility certificate, the Government could not refuse to act on that commitment without a valid reason. The principles of promissory estoppel and substantive legitimate expectation also prevented the State from resiling from its unequivocal promise. The withholding of the certificate was unsupported by any rescission of the notification or any legally sustainable ground.

Conclusion: The respondents were not entitled to withhold the eligibility certificate, and the petitioner was entitled to its issuance.

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