JUDGMENT :

A.K. Patnaik, J. - This batch of writ petitions relate to withdrawal of sales tax incentives granted by the State Government of Orissa under different Industrial Policy Resolutions (in short, "IPR"). Since common questions of fact and law arise in these writ petitions, they were heard analogously and are being disposed of by this common judgment.

Facts of individual cases as stated in the writ petitions:

2. O.J.C. No. 9967 of 1999 (Petitioner--Shree Jagannath Packers) :

By IPR, 1989 the Government of Orissa declared, inter alia, that exemption will be allowed to new small-scale industrial units set up in the State of Orissa from tax on purchases of spare parts of machinery, raw materials and packing materials and on sale of finished products for a period of 7 years from the date of commencement of commercial production. This was followed up by Finance Department notifications under the Orissa Sales Tax Act, 1947 granting the said exemptions. Encouraged by the said declaration, the petitioner set up a small-scale industrial unit for manufacturing of card-board boxes and corrugated card-board boxes by investing money from his own personal resources as well as from out of the loans from the State Bank of India in the year 1991. A permanent registration certificate thereafter was granted by the General Manager, District Industries Center, Cuttack indicating therein that the date of commercial production of the small-scale industrial unit of the petitioner is September 11, 1993 and the petitioner was entitled to enjoy the aforesaid benefits of exemption from sales tax for a period of seven years up to September 11, 2000. The petitioner enjoyed the said benefits of sales tax exemption from September 11, 1993 but on July 30, 1999 Notifications Nos. 622 of 1999, 623 of 1999, 624 of 1999 and 625 of 1999 were issued by the Government of Orissa in the Finance Department withdrawing all such benefits with effect from the 1st August, 1999. Aggrieved, the petitioner has filed this writ petition praying for quashing the said notifications dated 30th of July, 1999.

3. O.J.C. No. 13017 of 1999 (Petitioner--Larsen Toubro Co. Ltd.) :

Under IPR 1989 the State Government of Orissa declared, inter alia, that pioneer industrial units set up in zone "C" will be allowed deferment of payment of sales tax collected on finished products for a period of 9 years from the date of commercial production and in lieu of such deferment such pioneer industrial unit can opt for exemption of sales tax on finished products for a period of seven years from the date of commercial production. This was followed by notifications issued by the State Government of Orissa granting deferment of payment of tax under the Orissa Sales Tax Act, 1947 and under the Central Sales Tax Act, 1956 for a period of seven years from the date of commercial production. Encouraged by the said declarations, the petitioner set up a new industry at mouza-Arda in Jharsuguda located in Zone "C" named M/s. L & T Cement works with a capacity of 0.7 million tones per annum at a purchase cost of Rs. 80 crores and started commercial production with effect from September 10, 1993. Hence, the petitioner was entitled to deferment of payment of tax under the Orissa Sales Tax Act and the Central Sales Tax Act for a period of seven years up to September 9, 2000 and accordingly the petitioner applied to the Director of Industries, Orissa, for necessary certificate. But the notifications S.R.O. Nos. 623 and 624 of 1999 dated July 30, 1999 were issued withdrawing the benefit of deferment of payment of tax under the Orissa Sales Tax Act and the Central Sales Tax Act. Aggrieved, the petitioner has prayed for quashing the said two notifications issued by the State Government in the Finance Department.

4. O.J.C. No. 2718 of 2000 (Petitioner--IFGL Refractories Ltd.) :

Under IPR 1989 the State Government of Orissa declared, inter alia, that large scale industrial units would be eligible for deferment of payment o