Promissory estoppel cannot override VAT law where statutory input-tax credit on stock transfers is not permitted.

Denial of input-tax credit on stock transfers outside the State was upheld because the existing statutory scheme under the Haryana Value Added Tax Act did not permit such credit. The challenge based on a white paper failed, as a policy declaration cannot override the statute or compel the State to legislate in accordance with it. Promissory estoppel was also unavailable, since that doctrine cannot be used to enforce a representation that conflicts with the governing fiscal law or to secure a tax benefit not authorised by law.

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Issues: Whether denial of input-tax credit on stock transfer outside the State could be challenged on the basis of the white paper and the doctrine of promissory estoppel.

Analysis: The petition questioned the clarification under section 56(3) of the Haryana Value Added Tax Act, 2003 and the restriction under section 8(1) of the Act on input-tax credit for goods transferred outside the State. The Court held that the petitioner was not entitled to such credit under the existing statutory scheme. A policy declaration in a white paper could not compel the State to act contrary to the law or to enact legislation giving effect to the declaration. The doctrine of promissory estoppel cannot be invoked to require performance of a promise that conflicts with the existing legal framework.

Conclusion: The challenge to denial of input-tax credit failed, and the petition was liable to be dismissed.

Final Conclusion: Policy assurances in a white paper do not override the statute, and promissory estoppel cannot be used to secure relief contrary to the governing fiscal law.

Ratio Decidendi: Promissory estoppel cannot be enforced to compel the State to act contrary to an existing statute or to grant a fiscal benefit not permitted by law.

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