In Brief
A textile company sought to retain tax exemptions granted under a BIFR revival scheme. The State withdrew these exemptions years later, arguing they violated sales tax law which requires exemptions for a class of persons, not individuals. The Supreme Court upheld the withdrawal, holding that: (1) the single-unit exemption was ultra vires the statute; (2) promissory estoppel cannot enforce unlawful promises; (3) exemptions cannot continue indefinitely after revival; and (4) public interest in statutory compliance outweighs the company's expectations. The appeal was dismissed.
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