The judgment of the Court was delivered by

G. T. NANAVATI, J. - The case of the petitioner is that relying upon the sales tax incentive scheme for new industries declared by the Government on December 22, 1977 and August 27, 1980, it has set up a new industry to manufacture mild steel wires out of iron strips in a backward area. It started commercial production on July 23, 1981. Eligibility certificate was granted by the Industries Commissioner on December 17, 1982. Exemption certificate was granted by the sales tax authorities on February 6, 1982. In order to give effect to the scheme, the Government had also issued a notification on February 5, 1981 under section 49(2) of the Gujarat Sales Tax Act, 1969, by inserting entry No. 118 in the Schedule to the parent notification of 1970. However, by a subsequent notification dated August 17, 1982, the Government, in exercise of the powers under section 49(2) of the Act, amended entry at serial No. 118 and included the industry of "wire-drawing of steel and items requiring wire rods as essential raw materials" in the list of the excluded industries. Respondent No. 2 thereafter issued a notice to the petitioner stating therein t