Sanjay Karol, J.

The points which arise for consideration in the present petition are: (i) (a) as to whether petitioner is entitled to the incentives of reduction in the rates of excess duty only in terms of vide notification dated 27.07.2012 (Annexure PB); (b) as to whether notifications dated 17.08.2012 and 04.03.2014 (Annexures PC and PC-1 respectively) are applicable only to large industrial units established prior to 01.04.2012; (ii) if not, then as to whether respondents, on facts and in law are estopped from charging the excisable duty in excess of notifications Annexures PC and PC-1; and (iii) as to whether petitioner is entitled to interest on the excess amounts so deposited under protest.

2. Answer to the same would lie in application of two fundamental principles of law: (a) doctrine of promissory estoppel and (b) interpretation of fiscal statute and subordinate legislation.

3. The Government of Himachal Pradesh, took a conscious decision of providing certain incentives to all new industrial units to be established in the State of Himachal Pradesh. As such, by