( 1 ) THE petitioner is a public limited company incorporated under the Companies Act, having its registered office in Tamil Nadu and factory at jayanthipuram in the State of Andhra pradesh. The petitioner company is engaged in the manufacture of cement and is a registered dealer on the rolls of the commercial Tax Officer, Nandigama, the 5th respondent herein. The petitioner company applied for deferment of sale tax under G. O. Ms. No. 117 Industries and commerce Department dated 17-3-1993 as amended by G. O. Ms. No. 386 Industries and Commerce (IFR) Department dated 26-9-1994. The petitioner expanded the unit in order to increase the production of cement. By virtue of G. O. Ms. No. 117, as amended G. O. Ms. No. 386, referred to above, the petitioner is entitled for deferment of tax in respect of additional quantity of cement produced consequent to the expansion of the unit. The expansion of the unit leading to increase in production of cement took place with effect from 15-2-1995. Under the deferment of sales tax scheme, the petitioner company was entitled for deferment of sales tax/tax holiday even in respect of additional quantity produced consequent to the expansion of its unit. The petitioner company, therefore, applied for deferment of the sales tax on 10-8-1995. The said application was filed before the commissioner of Industries, Andhra Pradesh, hyderabad, the 3rd respondent herein. The 3rd respondent on consideration of the said application issued the proceeding no. 20/3/6/0734, dated 15-5-1996. It reads: government of Andhra Pradesh commissionerate of Industries office of the Commissioner of Industries, a. P. , Hyderabad no. 20/3/6/0734 Dated 15-5-1996 final Eligibility Certificate fixing up eligibility for Sales Tax Deferment/sales tax exemption for Expansion/ new Comprehensive Scheme of State incentive Scheme, 1992 g. O. Ms. No. 117 Industries and Commerce (IFR) Department, dated 17-3-1993 and g. O. Ms. No. 386 Industries and Commerce (IFR) Department, dated 26-9-1994