The doctrine of promissory estoppel cannot compel the government to act against statutory provisions governing entitlement to incentives.

1. This writ petition was filed seeking declaration that the petitioner is entitled to the incentive of Interest Free Sales Tax Loan under the Scheme introduced by the first respondent in G.O.Ms. No. 224, Industries and Commerce Department, dated 9-3-1976 by holding that the provisions of A.P. Interest Free Sales Tax Loans for Industries (Imposition of Ceiling) Act, 1987 (hereinafter referred to as 'the Act') does not affect the rights of the petitioner to claim the above mentioned incentive.

2 The writ petition was filed on the basis of the following facts alleged in the affidavit filed in support of the writ petition.

3. The petitioner, which is a Public Limited Company having its registered Office at Adoni, is engaged in the business of manufacture of Caustic Soda and other allied products. It was set up at Gandiparla Village, Kurnool District, which is an industrially backward area. The unit is established at a total cost of Rs. 30 (thirty) crores with the collaboration of an Italian Company - M/s Oronzio De Nora Impaianti, Milani, Italy. Government of Andhra Pradesh in G.O. Ms. No. 224, Industries and Commerce Depart­ment, dated 9-3-1976 introduced new Scheme of State incentives for new industries to be set up in the State of Andhra Pradesh. According to the Scheme, the industries which go in to regular production on or after 1-1-1976 as well as such of those existing industries effect­ing substantial expansion are eligible for the incentives. One of the important incentives offered under the said G.O. Ms. No. 224, dated 9-3-1976 was Interest Free Sales Tax Loan. Entrepreneurs setting up industries will be eligible for Interest Free Sales Tax Loan equal to the tax paid by them under Andhra Pradesh General Sales Tax Act on construc­tion material, plant and machinery equip­ment, during the pre - production stage and purchase or sales tax paid by them under the said Act for a period of five years from the date of going into regular production on raw - ­material, components and finished goods. Each year's loan is repayable in full at the end of the 10th year from the date of drawing such loan. The life of the scheme was for a period of five years expiring by 31-12-1980. Thereafter, the Government in G.O.Ms. No. 736, Indus­tries and Commerce (II and CP) Department, dated 28-12-1981 extended the incentives beyond 31-12-1980 till a revised Scheme is introduced.

4. It was further stated in the affidavit that by G.O. Ms. No. 375 Industries and Commerce (IA) Department dated 23-8-1985, revised package of State incentives were offered with the object of industrialisation and restricted the same to the identified three intensive industrial areas, viz., Adilabad, Srikakulam and Anantapur Districts. Kur­nool District was not included in the same. Even so, by another G.O. Ms. No. 437 Industries and Commerce (IA) Department, dated 10-10-1985, the Scheme of incentives offered in G.O. Ms. No. 224 dated 9-3-1976 was extended up to 28-9-1983. Thereafter, registration of applications seeking incentives under G.O. Ms. No. 224 dated 9-3-1976 was stopped with effect from 29-8-1983. Subsequently, by G.O. Ms. 433, Industries and Commerce (IA) Department, dated 31-7­ - 1986, registration of applications claimi