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    <title>2025 (5) TMI 636 - GAUHATI HIGH COURT</title>
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    <description>After a GST-linked restructuring of an industrial reimbursement scheme, promissory estoppel could not be invoked to compel continuation of the earlier incentive beyond the revised legal and fiscal framework. The withdrawal of the power to extend the eligibility period was therefore not invalid on that ground. However, where pending extension applications had been filed before the amendment and similarly situated units had already received extensions, the State was required to show a rational basis for the differential treatment. In the absence of such justification, the non-consideration of the petitioners&#039; applications was arbitrary and offended Article 14, entitling them to fresh consideration on the same yardstick as comparable units.</description>
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    <pubDate>Tue, 29 Apr 2025 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=770364</link>
      <description>After a GST-linked restructuring of an industrial reimbursement scheme, promissory estoppel could not be invoked to compel continuation of the earlier incentive beyond the revised legal and fiscal framework. The withdrawal of the power to extend the eligibility period was therefore not invalid on that ground. However, where pending extension applications had been filed before the amendment and similarly situated units had already received extensions, the State was required to show a rational basis for the differential treatment. In the absence of such justification, the non-consideration of the petitioners&#039; applications was arbitrary and offended Article 14, entitling them to fresh consideration on the same yardstick as comparable units.</description>
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