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Promissory Estoppel Cannot Override Statutory Provisions; Government Not Bound by Past Representations per CGST Act Section 174(2)(c).

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....Doctrine of promissory estoppel could operate against a statute or not? - benefits granted under an earlier statute, - Even on the ground of change of policy, which is in public interest or in view of the change in the statutory regime itself on account of the GST Act being introduced as in the instant case, it will not be correct to hold the Union bound by the representation made by it, i.e. by the said O.M. of 2003. Further, this would be contrary to the statutory provisions as enacted under Section 174(2)(c) of the CGST Act - SC....