Tax incentive policy alone creates no enforceable right to remission or deferment without statutory backing.

An incentive scheme framed as a policy statement did not, by itself, confer an enforceable right to sales tax remission or deferment. Fiscal benefit could arise only from statutory authority, and the amended rules did not extend the additional benefit to food processing industries in the appellant's category. Promissory estoppel also failed because the appellant did not plead or establish a clear promise, detrimental alteration of position, or resulting inequity. The writ petition was therefore rightly rejected, and no enforceable entitlement to tax relief was made out.

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Issues: Whether the appellant was entitled to remission or deferment of sales tax under the incentive scheme despite the amended rules not extending the benefit to food processing industries, and whether promissory estoppel could be invoked in the absence of specific pleadings.

Analysis: The incentive scheme was only a policy statement and could not, by itself, create an enforceable right to tax remission or deferment. Such fiscal benefit could arise only from a statutory provision, and the amendment to the rules did not extend the additional benefit to food processing industries in the appellant's category. The appellant did not plead or establish the ingredients of promissory estoppel, namely a clear promise, alteration of position to prejudice, and resulting inequity in permitting the State to resile. In the absence of an enforceable legal right, the rejection of the writ petition was found to be justified.

Conclusion: The appellant had no enforceable right to claim remission or deferment of tax, and the challenge failed. The plea of promissory estoppel was not accepted.

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