Judgment

ALAGIRISWAMI, J. (for himself and on behalf of A. N. Ray, C. J. And H. R. Khanna, J.) :- The appeal and the writ petitions raise the question of interpretation of Section 21 (3) of the Andhra Pradesh Sugarcane (Regulation of Supply and Purchase). Act, 1961. The appellant and the petitioners are sugar factories in the State of Andhra Pradesh. They applied under the provisions of Section 21 (3) for exemption from the tax payable under sub-section (1) of that section on the ground that they, having substantially expanded, were entitled, to the extent of such expansion, to exemption from the payment of tax. The Government of Andhra Pradesh having refused that request these writ petitions have been filed before this Court contending that the decision denying them exemption is contrary to Section 21 (3) which does not countenance any classification and that the classification adopted is based on no nexus to the object of the Act. The appeal is against the decision of the Andhra Pradesh High Court dismissing a writ petition filed for similar relief.

2. Two contentions, one regarding promissory estoppel and another regarding the exemption given to Sarvaraya Sugars Ltd. were not pres