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HC held that while the State's tax exemption policy amendment under GST regime was valid, the arbitrary non-consideration of petitioners' extension applications compared to other similarly situated industries violated Article 14. The court directed respondent authorities to reconsider petitioners' claims within 60 days using identical evaluation criteria applied to other units. The doctrine of promissory estoppel was not applicable given public policy considerations and legal regime changes. Petitioners' claims for full tax exemption were rejected, but they were granted an opportunity for fair administrative review of their extension applications.
HC held that while the State's tax exemption policy amendment under GST regime was valid, the arbitrary non-consideration of petitioners' extension applications compared to other similarly situated industries violated Article 14. The court directed respondent authorities to reconsider petitioners' claims within 60 days using identical evaluation criteria applied to other units. The doctrine of promissory estoppel was not applicable given public policy considerations and legal regime changes. Petitioners' claims for full tax exemption were rejected, but they were granted an opportunity for fair administrative review of their extension applications.
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