Promissory estoppel does not bar clarificatory excise notifications issued in public interest and for revenue protection.

The HC followed the binding Supreme Court ruling in connected excise exemption litigation and held that the impugned notifications withdrawing or reducing the duty exemption were not barred by promissory estoppel. The notifications were treated as clarificatory measures issued in public interest and in the interest of revenue, so the challenge to their validity could not succeed. As no surviving issue remained on the legality of the notifications or any entitlement to continuance of full exemption, the writ petition was dismissed.

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Issues: Whether the impugned excise notifications withdrawing or reducing the exemption from duty were liable to be quashed on the ground of promissory estoppel and whether the petitioner was entitled to continuance of 100% exemption.

Analysis: The challenge to the notifications was covered by the authoritative decision of the Supreme Court in the connected excise exemption litigation, which held that the impugned notifications were not hit by promissory estoppel and were clarificatory in nature, issued in public interest and in the interest of revenue. In view of that pronouncement, no surviving issue remained for adjudication on the validity of the notifications or the claimed entitlement to full exemption.

Conclusion: The challenge to the notifications failed and the petitioner was not entitled to the claimed 100% exemption.

Final Conclusion: The writ petition was dismissed following the binding Supreme Court decision upholding the legal validity of the impugned excise notifications.

Ratio Decidendi: A fiscal exemption notification may be treated as valid and enforceable despite an earlier exemption regime where the later notification is held to be clarificatory and justified by public interest and revenue considerations, and promissory estoppel does not bar such a change.

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