Promissory estoppel cannot extend an excise exemption beyond the express period fixed by statutory notification.

Promissory estoppel could not extend a fiscal concession beyond the express period fixed in the exemption notifications. The Press Note was only a policy indication and did not create an enforceable right to concessional excise duty for five years from commencement of production. Excise liability remained governed by the statute and the relevant tariff item, and the notifications limited the concession to 31 March 1984. A ministerial statement in the House could not override the statutory scheme or enlarge the notified exemption. As production began only after the exemption period had ended, the petitioner was not entitled to the duty concession.

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Issues: Whether the petitioner was entitled to concessional excise duty for five years from the date of commencement of production on the basis of the Press Note and the Minister's statement, despite the exemption notifications being limited to 31 March 1984.

Analysis: The Press Note was only a policy indication and did not itself create an enforceable right to exemption. Excise duty liability was governed by the Central Excises and Salt Act and the relevant tariff item, and the concession was extended only through exemption notifications, each of which expressly limited the period of operation up to 31 March 1984. The petitioner commenced production only in September 1985, when no exemption notification was in force. A ministerial statement on the floor of the House could not override the statutory scheme or enlarge the period of exemption beyond what had been granted under the notifications. Promissory estoppel could not be invoked against the express terms of the statute and the notified exemption.

Conclusion: The petitioner was not entitled to claim excise duty concession beyond 31 March 1984, and the writ petition failed.

Ratio Decidendi: Promissory estoppel cannot be used to extend or create a fiscal exemption contrary to the express terms of the statutory notification governing the levy.

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