Promissory estoppel cannot override taxing statutes, and an unauthorised refund assurance will not bind the State.

Promissory and equitable estoppel could not be used to compel refund of sales tax, purchase tax, or inter-State sales tax where the alleged assurance was not a final, enforceable promise and the taxing statute formed a complete code governing exemption and refund. Executive representations could not override the statutory scheme, divert public revenue, or require the State to act beyond its authority. The Court therefore held that estoppel could not operate against statutory duties, legislative policy, or public interest in tax collection, and the claim for refund and related tax benefits failed.

---

---

Issues: Whether the State was bound by equitable estoppel or promissory estoppel to grant refund of sales tax, purchase tax and inter-State sales tax to the industrial unit, and whether such refund could be directed consistently with the taxing statute and public policy.

Analysis: The assurance theory was examined against the sequence of policy statements, departmental communications and later revised policy. The Court held that no final and enforceable commitment to grant the full refunds arose before the revised policy had come into force, and that the company's right, if any, could not be traced to a pre-existing concluded promise. More importantly, the taxing statute itself provided a complete code for exemption, refund and notifications, and did not permit refund outside the statutory framework. A representation by executive authorities could not be used to defeat the scheme of taxation, divert public revenues, or compel the State to do what the statute did not authorise. Equitable estoppel could not operate against statutory duties, legislative policy, or public interest in the collection and appropriation of tax.

Conclusion: The plea of equitable estoppel failed, and the company was not entitled to the claimed refund of sales tax and related tax benefits against the State.

Ratio Decidendi: Promissory or equitable estoppel cannot be invoked against the State to enforce an executive assurance that is unauthorised, contrary to the taxing statute, or inconsistent with public policy and the protection of public revenues.

---