J.ESWARA PRASAD, V.BHASKARA RAO
Roxy Roller Flour Pvt. Ltd. – Appellant
Versus
Government Of A. P. – Respondent
( 1 ) IN this batch of writ petitions the constitutional validity of G. O. Ms. No. 561, Revenue (CT-II) Department, dated 26/03/1993, is the subject-matter of challenge on several grounds and hence this common judgment. Earlier to the issuance of the above impugned G. O. , the Government of Andhra Pradesh through G. O. Ms. No. 377, Revenue, dated 2/05/1991, exempted wheat and wheat products for a period of five years, from payment of sales tax.
( 2 ) THAT exemption under that G. O. is now rescinded through the present impugned G. O. even before the expiry of five years period covered thereunder.
( 3 ) EARLIER to the issuance of the rescinded G. O. , the Andhra Pradesh Roller Flour Mills Association had by its best attempts and through incessant persuasions obtained the exemption from sales tax through the said G. O. In fact, there were proceedings, in Writ Petition No. 12391 of 1989 dated 2/02/1990 [reported as Prabhudayal Ramanand v. State of A. P. [1990] 77 STC 122 (AP ). ], that even preceded the issuance of the rescinded G. O.
( 4 ) THE impugned G. O. dated 26/03/1993, is sought to be assailed by invoking, mainly, (1) the doctrine of promissory estoppel, (2)
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