Promissory estoppel and parity failed for Central Sales Tax exemption where later policy left the levy to separate notification.

A later incentive regime confined concessions to State sales tax and State excise duty, leaving Central Sales Tax exemption to separate notification, so a unit established after the earlier policy could not rely on promissory estoppel or legitimate expectation to claim such exemption. Parity with earlier exempted units was also unavailable because the date of establishment was a legally material distinction under the policy framework. The Court further noted that an efficacious statutory appeal existed under the Central Sales Tax regime and that the petitioner had already pursued review, making writ interference with the assessment, demand and recovery proceedings inappropriate under Article 226.

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Issues: (i) Whether the petitioner could claim exemption from Central Sales Tax on the basis of promissory estoppel and legitimate expectation arising from the earlier industrial policy and incentive notifications; (ii) Whether the petitioner was entitled to parity with other industrial units that had received Central Sales Tax exemption; (iii) Whether the assessment, review, demand and recovery proceedings were liable to be interfered with in writ jurisdiction despite availability of an alternative statutory remedy.

Issue (i): Whether the petitioner could claim exemption from Central Sales Tax on the basis of promissory estoppel and legitimate expectation arising from the earlier industrial policy and incentive notifications.

Analysis: The petitioner's unit was established after the earlier industrial policy had ceased to operate and during the currency of the later incentive regime. The later notification granted concessions only in relation to State sales tax and State excise duty, while Central Sales Tax exemption was left to be governed by separate notifications or orders. The materials on record also showed that the petitioner itself had sought a separate exemption notification under the Central Sales Tax law, which was inconsistent with the claim that such exemption had already accrued under the earlier policy.

Conclusion: The claim based on promissory estoppel and legitimate expectation failed and was rejected, against the petitioner.

Issue (ii): Whether the petitioner was entitled to parity with other industrial units that had received Central Sales Tax exemption.

Analysis: The comparator units had been set up before the earlier policy ceased to operate, whereas the petitioner's unit was established later. The distinction in the dates of establishment was held to be legally material for eligibility, and the different treatment was therefore justified by the applicable policy framework.

Conclusion: The plea of parity was rejected, against the petitioner.

Issue (iii): Whether the assessment, review, demand and recovery proceedings were liable to be interfered with in writ jurisdiction despite availability of an alternative statutory remedy.

Analysis: The Court held that an efficacious statutory appeal was available under the Central Sales Tax regime. In addition, the petitioner had already pursued review before the assessing authority. For that reason, the impugned assessment-related orders were not fit for interference under Article 226.

Conclusion: Interference with the assessment, review, demand and recovery proceedings was declined, against the petitioner.

Final Conclusion: No enforceable right to Central Sales Tax exemption was established, and the writ petition as a whole was dismissed.

Ratio Decidendi: Where a later incentive regime expressly confines concessions to State levies and leaves Central Sales Tax exemption to separate governmental notification, a unit established after the earlier policy regime cannot claim Central Sales Tax exemption on promissory estoppel, legitimate expectation, or parity; writ interference is also unwarranted when an efficacious statutory remedy exists.

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