JUDGMENT - MOHTA V.A., J.:—The common referred point for consideration by this Full Bench in this batch of petitions is :—

“Whether regulations framed under section 157 of he Customs Act can be termed as 'statute' and whether doctrine of promissory estoppel can be evoked against such regulations?”

2. All the petitioners are dealers in photographic and other processes. They entered into contracts with manufacturers of mini colour lab in Japan for import of sets of N.QSS. 603 With accessories and spare parts, and opened irrevocable letters of credit for the price in Japanese currency Yen. All this was complete much before 3rd April, 1986. Indeed the sets even left Japan shore before that date. The sets, however, actually reached India subsequent to that date. The significance of the date 3rd April, 1986 is that the Project Import Regulations, 1986 made under section 157 of the Customs Act (the Act) were brought in force with effect from that date by Notification No. 230 of 1986 in supersession of the Project Imports (Registration of Contract) Regulations, 1965 made under section 157 read with proviso to the entry in Column No. 2 against Item 72-A(i) of the First Schedule to the India

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