Area-based excise exemption ends when the notified area is deleted, and promissory estoppel cannot extend tax relief.

Area-based excise exemption was confined to units located in the designated backward area covered by Notification No. 50/2003-CE, and once the relevant Khasra number was deleted by Notification No. 27/2005, the unit ceased to qualify from the date of amendment. The Tribunal held that entitlement had to be tested strictly against the governing notification, and promissory estoppel could not extend a tax exemption beyond the statutory notification. The excise duty demand was therefore upheld, along with the related treatment of Cenvat credit.

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Issues: Whether the appellant was entitled to area based exemption under Notification No. 50/2003-CE after the relevant Khasra number was deleted by Notification No. 27/2005, and whether the doctrine of promissory estoppel could continue the exemption.

Analysis: The exemption was available only to units situated in the designated backward area covered by the notification. Once the area in which the appellant's unit was located was deleted from the notification, the unit ceased to be covered by the exemption from the date of amendment. The Tribunal held that the dispute had to be decided on the basis of the governing notification and that equitable relief based on promissory estoppel could not override the statutory notification in tax matters before the Tribunal.

Conclusion: The appellant was not entitled to the exemption after the amendment, and the demand of excise duty with the related relief for Cenvat credit was upheld against the appellant.

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