In Brief
A manufacturing company operating a captive power plant in Jharkhand claimed a 50% electricity duty rebate for three fiscal years (2011-12, 2012-13, 2013-14) under the State's Industrial Policy 2012. The State issued the exemption notification on January 8, 2015, nearly three years late and with prospective effect only. The Supreme Court held the respondent entitled to the rebate for FY 2012-13 and 2013-14 (but not 2011-12), reasoning that the State's solemn representation in the Industrial Policy created a legitimate expectation protected by Article 14. The delay and prospective application were held arbitrary and in breach of the policy's commitment to issue follow-up notifications within one month. Technical defences (non-claim in returns, filing delay, unjust enrichment) were rejected. The entitlement was limited to the period following the date of production per the policy's express terms.</summary_100>
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