Sales tax exemption requires statutory grant by the taxing authority; eligibility certificates and policy assurances alone do not create entitlement.

An eligibility certificate issued by the Industries Department does not, by itself, create an enforceable right to sales tax exemption; the exemption must be granted under the governing sales tax statute and the Punjab General Sales Tax (Exemption and Deferment) Rules, 1991 by the competent taxing authority. A claim based on amended industrial policy also fails where the unit remains within the negative list and no binding representation is shown. On that basis, the doctrines of equitable estoppel and legitimate expectation could not compel exemption in the absence of a valid exemption under the sales tax regime, and the challenge to rejection was dismissed.

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Issues: Whether the petitioner was entitled to sales tax exemption on the basis of the Industries Department's eligibility certificate and the amended industrial policy, and whether the doctrines of equitable estoppel and legitimate expectation could compel grant of exemption in the absence of exemption under the sales tax rules.

Analysis: The exemption claim was governed by the Punjab General Sales Tax Act and the Punjab General Sales Tax (Exemption and Deferment) Rules, 1991. An eligibility certificate from the Industries Department did not by itself create an enforceable right to sales tax exemption, because the operative exemption had to be granted by the Excise and Taxation Department in the manner prescribed by the rules. The record also showed that the unit remained within the negative list under the relevant sales tax regime and that the claimed administrative assurance did not amount to a binding representation capable of attracting equitable estoppel or legitimate expectation.

Conclusion: The petitioner was not entitled to the sales tax exemption, and the challenge to the rejection order failed.

Final Conclusion: The writ petition was held to be without merit and was dismissed.

Ratio Decidendi: An eligibility certificate or policy indication from the Industries Department does not, by itself, confer entitlement to sales tax exemption unless the exemption is granted under the governing sales tax statute and rules by the competent taxing authority.

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