Promissory estoppel could not override the sales tax statute, defeating the claim for industrial policy concessions.

The Industrial Policy, 1986 incentives could not override the Assam Industries (Sales Tax Concessions) Act, 1986, because the statute did not create a corresponding enforceable right to sales tax exemption. Promissory estoppel therefore could not be invoked against the statute to compel concession under the policy. The controversy was also already covered by an earlier Division Bench ruling rejecting the same estoppel claim, and the court found no reason to depart from that view. The exemption claim accordingly failed in favour of the Revenue.

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Issues: Whether the doctrine of promissory estoppel could be invoked to compel grant of sales tax concessions under the industrial policy after the coming into force of the Assam Industries (Sales Tax Concessions) Act, 1986, and whether the appeals were covered by the earlier Division Bench decision.

Analysis: The Scheme under the Industrial Policy, 1986 contemplated incentives for eligible industrial units, but the subsequent enactment regulating sales tax concessions did not create a statutory right to exemption corresponding to the scheme. Once the Act came into force, any promise under the policy could not override the statute. The Court also noted that the controversy was already governed by the earlier Division Bench ruling, which had rejected the same promissory estoppel claim, and found no reason to differ from that view.

Conclusion: The doctrine of promissory estoppel could not be used against the statute, and the claim for sales tax exemption failed in favour of the Revenue.

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