Promissory estoppel limits withdrawal of excise concessions when industry reliance and public-interest justification are absent.

Promissory estoppel can bind the Government where a tax concession notification induces a party to alter its position and complete project investments in reliance on the representation. A later policy change, by itself, is insufficient to justify withdrawal; the Government must show overriding public interest with proper supporting material. The fact that the concession was granted through delegated or subordinate legislation does not exclude estoppel in such circumstances. On these facts, the withdrawal notification was held unsustainable because no adequate public-interest basis was established for unilateral revocation of the excise concession.

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Issues: Whether the Central Government could validly withdraw the excise concession granted under the notification despite the assessee having acted upon the earlier scheme, or whether promissory estoppel bound the Government.

Analysis: The notifications formed part of an integrated excise concession scheme meant to encourage tyre industries. The assessee set up and expanded its unit, obtained finance and industrial approvals, and completed its project in reliance on the governmental representation. A change in policy by itself was held insufficient to defeat estoppel. The Government had to show overriding public interest with proper material, and no adequate basis was established to justify unilateral withdrawal. The fact that the power was exercised under delegated or subordinate legislation did not exclude promissory estoppel in these circumstances.

Conclusion: The withdrawal notification was not sustainable, and promissory estoppel operated against the Government in favour of the assessee.

Ratio Decidendi: Promissory estoppel applies against the Government when a statutory or subordinate legislative representation induces a party to alter its position, and withdrawal of that representation is impermissible absent legally sufficient overriding public interest.

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