JUDGMENT The judgment of the Court was delivered by G. T. NANAVATI, J. - These writ petitions raise a common question and, therefore, they are heard together and disposed of by this judgment. It is the case of the petitioners that relying upon the Government resolution dated 22nd December, 1977 and 27th August, 1980, they had established a new industry for manufacturing khandsari from sugarcane and had, thus, become entitled to the benefit of purchasing free of sales tax raw materials, packing materials and processing materials utilised for the purpose of manufacturing khandsari. In spite of that, the respondents are refusing to grant benefit of sales tax exemption with respect to the purchase of materials, namely, sugarcane. The first petitioner is Special Civil Application No. 103 of 1985 is a partnership firm. It came into existence on 1st April, 1981. Immediately thereafter, they acquired land and obtained registration as a small-scale industrial unit. It completed the construction work and started commercial production on 8th February, 1982. By that time, it had invested about Rs. 19,70,177. The Industries Commissioner granted eligibility certificate on 27th January, 1983. In view of the Notification dated 5th February, 1981, whereby exemption from payment of purchase tax payable under section 15 of the Gujarat Sales Tax Act, 1969, only has been granted, the petitioners, apprehending that the Government was trying to back out of its promise by not extending similar benefits with respect to the tax payable under section 18 of the Act, have filed Special Civil Application No. 103 of 1985. In Special Civil Application No. 2033 of 1985, the first petitioner is a partnership firm. It came into existence on 21st July, 1980. It invested about Rs. 26,02,701 and started commercial production on 15th January, 1981. The Industries Commissioner granted eligibility certificate on 25th November, 1982. As the petitioners of this petition are having similar apprehension as was entertained by the petitioners in Special Civil Application No. 103 of 1985, they have filed this petition. The petitioner in Special Civil Application No. 6038 of 1986 is also a partnership firm. It was constituted on 12th March, 1981 and after setting up a factory, it started commercial production on 15th February, 1982 and obtained eligibility certificate on 22nd December, 1982. The petitioner in Special Civil Application No. 6038 of 1986 is also a partnership firm. It was constituted on 12th March, 1981 and after setting up a factory, it started commercial production on 15th February, 1982 and obtained eligibility certificate on 22nd December, 1982. The petitioner's claim for exemption from payment of purchase tax on the sugarcane utilised for manufacture of khandsari was not accepted by the Sales Tax Officer and he passed assessment orders accordingly for Samvat Years 2038 and 2039. The petitioner is challenging these orders of assessment and also wants this Court to issue a direction to the respondents that they are bound to carry out the promise contained in Government resolution dated 27th August, 1980 and for that reason, they should not recover any purchase tax from the petitioner under section 18 of the Act. Even though all the petitioners have challenged the validity of the notification dated 5th February, 1981, issued under section 49 of the Act, the learned counsel appearing for the petitioners stated that they are not now challenging the said notification and that they are basing their claim only on the doctrine of promissory estoppel. It is, therefore, not necessary to consider other contentions raised in the petitions and the only point, which really arises for consideration, is whether any representation was made by the Government either by its resolution dated 22nd December, 1977 or the resolution dated 27th August, 1980, that new industrial units will be entitled to purchase raw materials, including sugarcane, without payment of purchase tax under any of the sections, including section 18 of the Act. In order to appreciate what was the representation made by the Government by its resolutions dated 22nd December, 1977 and 27th August, 1980, it will be useful to set out the relevant parts or said two resolutions. The relevant part of the resolution dated 22nd December, 1977, reads as under : "............ (i) Exemption from sales tax : (5) The scheme applies to all new small-scale industrial units commissioned on or after 1st November, 1977, in areas beyond 24 kms. from the municipal limits of Ahmedabad and Baroda and 10 kms. from the municipal limits of Surat, Rajkot, Bhavnagar and Jamnagar and also not located in towns/cities/villages having a population of more than 1 lakh on the basis of 1971 census. from the municipal limits of Ahmedabad and Baroda and 10 kms. from the municipal limits of Surat, Rajkot, Bhavnagar and Jamnagar and also not located in towns/cities/villages having a population of more than 1 lakh on the basis of 1971 census. All such small-scale industrial units are entitled to purchase free of tax machinery and equipment, raw materials, packing materials and processing materials, utilised by them for the purpose of manufacturing goods for sale on their obtaining eligibility certificate from the Commissioner of Industries or any officer so authorised by him and sales tax exemption certificate from the Commissioner of Sales Tax or an officer authorised by him. ................" The relevant part of the resolution dated 27th August, 1980, reads as under : "............ (6) Sales tax incentives : Under this scheme all the industrial units eligible as per paras 2 and 3 will have an option to choose one of the following two sales tax incentives : (i) Sales tax exemption incentives; (ii) Sales tax deferment incentives. Benefits available under each of these two incentives are as specified below : (A) Under sales tax exemption incentive a unit will be entitled to purchase free of sales tax, raw materials, packing materials and processing materials utilised for the purpose of manufacturing goods. In addition to this it will also be exempted from payment of sales tax on sale of goods manufactured by it. The quantum of sales tax exemption will be as under : ............." What is contended by the learned counsel for the petitioners is that by passing those resolutions and publishing the same, the State Government made a clear representation that the eligible industrial units would be entitled to purchase free of sales tax raw materials, packing materials, and processing materials utilised by them for the purpose of manufacturing goods for sale. It was submitted that, though both the resolutions provided for exemption from sales tax, really what was intended was exemption from payment of purchase tax and accordingly, exemption notifications under section 49 of the Act were issued, granting exemption from payment of purchase tax payable under section 15 of the Act. Thus, there is no controversy on the point that, under both the resolutions, exemption, which was to be granted, was in respect of payment of purchase tax. Thus, there is no controversy on the point that, under both the resolutions, exemption, which was to be granted, was in respect of payment of purchase tax. Only dispute, as we have stated above, is whether the representation that was made by the Government was that exemption was to be granted in respect of purchase tax payable under any of the sections of the Act or that it was to be granted in respect of the purchase tax payable under section 15 of the Act only. If it is held that the Government had promised to grant exemption from payment of purchase tax under section 15 only, then it will have to be held that the petitioners had remained liable to pay purchase tax for their purchases of sugarcane. If it is held that the representation, which the Government made was that, no purchase tax whatsoever was to be paid in respect of raw materials utilised by the eligible industrial units for the purpose of manufacturing their goods, then, in that case, even though the Government had not issued any notification under section 49 in that behalf, it will have to be further held that the Government is bound by its promise and it must extend the benefit of exemption to the petitioners in respect of their purchases of sugarcane also. Relevant paragraphs of the resolutions, which have been set out above, do not contain any words of limitation, suggesting that raw materials, which were in contemplation of the Government, were raw materials other than sugarcane. It was, therefore, argued by the learned counsel for the petitioners that the words "raw materials" should be interpreted to mean all raw materials, more particularly because of the object of the industrial incentive policy declared by the Government. It was submitted that the Government wanted industrial development of the State and also wanted development of the industries in rural areas and backward areas, to achieve a more balanced growth and also to have decongestion of industries from developed areas and cities, like Ahmedabad, Baroda and Surat. Thus, the industrial incentive policy was evolved for the purpose of encouragement of industry in the State and it was for that reason that benefits like cash subsidy, exemption from sales tax, giving of interest-free sales tax loans and deferment of sales tax were declared by the Government from time to time. Thus, the industrial incentive policy was evolved for the purpose of encouragement of industry in the State and it was for that reason that benefits like cash subsidy, exemption from sales tax, giving of interest-free sales tax loans and deferment of sales tax were declared by the Government from time to time. The declarations, which were made in this behalf were to the entrepreneurs and this fact should also be considered while trying to interpret the words "raw materials" and finding out what was the representation made by the Government. It was submitted that if benefit of exemption from payment of purchase tax in respect of purchase of sugarcane is denied to the industrial units manufacturing khandsari from sugarcane, then the very object of establishing such industries in the backward areas would be defeated because no such industry would have preferred to go to the rural or backward areas only for the benefits available with respect to the purchases of packing materials and processing materials only. It was also submitted that the 1980 scheme was a new scheme altogether and, therefore, with a view to find out what was the representation made under that scheme, we should look at the said scheme alone and not consider what the Government had done earlier. While appreciating these submissions, first thing that is required to be noticed is that both these resolutions have been passed by the Government in exercise of its administrative powers. In its resolution dated 27th August, 1980, it is clearly stated that these incentives are given under the discretionary power of the State Government. So far as granting of exemption from payment of sales tax is concerned, that could be done and was done by the Government in exercise of its statutory powers under the Act. We are referring to this difference in the nature of power, as it will have some bearing on the question as to what was the representation made by the State Government and not for the purpose of suggesting that no relief can be granted to the petitioners even if we come to the conclusion that the representation was also with respect to granting of exemption from payment of purchase tax under section 18 also. Another thing to be noted is that, though the schemes declared by the Government by its resolutions dated 22nd December, 1977 and 27th August, 1980, were new schemes, they were not altogether new, but they were in continuation of the same policy of the Government of encouraging new industries in the State. The resolution dated 27th August, 1980, refers to two earlier resolutions, one relating to cash subsidy and other relating to sales tax incentives, both dated 22nd December, 1977. It is further stated therein that the Government had introduced a package of incentives for promotion of industries in rural and backward areas to achieve a more balanced growth and avoid further congestion of developed areas and large cities. Thereafter it is stated that : "........ With a view to accelerate development of industries and strengthen the trend of industries coming to developing areas of the State, Government had decided to introduce a new scheme of sales tax benefits in lieu of the present sales tax exemption/loan scheme with effect from 1st June, 1980 ......." The cash subsidy scheme was retained and the scheme of sales tax benefit came to be modified. Earlier, it consisted of exemption from sales tax or interest-free sales tax loan. By that resolution, sales tax benefits in terms of exemption from sales tax was retained, with suitable modifications. It was found necessary that the said benefit was not to be extended to medium and large scale industries also. The benefit of interest-free sales tax loan was discontinued and instead of that, incentive by way of sales tax deferment was introduced. The areas of applicability and list of growth centres remained the same. The list of excluded industries also remained the same. So also, the definitions and other details remained the same as under the old scheme. Therefore, though the scheme declared by the resolution dated 27th August, 1980, is described as a new scheme, it was not altogether new and, therefore, it will not be proper to read the said resolution, for finding out the representation made therein, ignoring or disregarding what had happened earlier. In fact, the Government had introduced a scheme of exemption from sales tax to new industrial units from November, 1970, for the purpose of promoting industrial development in the State. That scheme was contained in the notification dated 11th November, 1970, issued under section 49 of the Act. In fact, the Government had introduced a scheme of exemption from sales tax to new industrial units from November, 1970, for the purpose of promoting industrial development in the State. That scheme was contained in the notification dated 11th November, 1970, issued under section 49 of the Act. According to that scheme, new industrial units commissioned on or after 1st April, 1970, in areas beyond 24 kms. from the municipal limits of cities of Surat, Rajkot, Bhavnagar and Jamnagar were, on obtaining eligibility certificate from the Industries Commissioner, Gujarat State, and the sales tax exemption certificate from the Commissioner of Sales Tax, Gujarat State, entitled to purchase free of tax machinery, raw materials, processing materials and packing materials utilised by them for the purpose of manufacturing any goods for sale. The scheme was then reviewed in July, 1971 and the Government decided to exclude 14 industries from the purview of the scheme of sales tax exemption. The scheme was again reviewed and the Government passed a resolution on 6th December, 1971, announcing further benefits, particularly benefit of sales tax concession in respect of sales tax payable by such new industrial units on the sale of their finished goods. Thereafter, by passing two separate resolutions on the same date, i.e., 22nd December, 1977, the Government announced two schemes, one known as "New industries scheme for cash subsidy for industrial units to be set up in developing areas" and the other known as "New industries - scheme for sales tax exemption and grant of loan in respect of amount of sales tax paid on sales of finished products". Incentives which were offered till then were not bound to be adequate by the Government and a need was felt for such incentives like interest-free sales tax loan and cash subsidy. It was also felt that the package of incentives should be used as an effective lever to assist in identifying right locations for the industries and as an effective instrument of promoting orderly, balanced and sustained industrial growth throughout the State. Thus, the scheme was so evolved so as to achieve those objectives and at the same time encourage establishment of new industries in the State. Thus, it was in pursuance of the said policy that these two resolutions came to be passed by the Government. Thus, the scheme was so evolved so as to achieve those objectives and at the same time encourage establishment of new industries in the State. Thus, it was in pursuance of the said policy that these two resolutions came to be passed by the Government. By Resolution No. MSC-1076-7637(1)-J, it declared the cash subsidy scheme and by Resolution No. MSC-1076-7637-(2)-J, it declared the other scheme. Whereas under the earlier scheme, benefit of sales tax exemption was available to all the new industrial units commissioned on or after 1st April, 1970, except those which were specifically excluded in July, 1971, under the 1977 Scheme, the benefit of sales tax exemption was confined to new small-scale industrial units. So far as new medium and large scale industrial units were concerned, they were given the benefit of interest-free sales tax loan. The list of excluded industries for the purposes of exemption from sales tax remained the same. While declaring the exemption from sales tax in almost the same words, it was further stated in the resolution that necessary notification in that regard would be issued by the Finance Department. Thereafter, the Government, in its Finance Department, did issue a notification dated 26th June, 1978, exercising its powers under section 49 of the Act and introduced entry 94 in the Schedule to the parent notification dated 29th April, 1970. By that notification, exemption from payment of tax was also granted in respect of sales of machinery and equipment, raw materials, packing materials and processing materials by a registered dealer to a specified manufacturer, meaning thereby a person establishing a new small-scale industry. But it is not necessary to consider that part of it, because in these cases raw materials were purchased by the petitioners not from registered dealers, but directly from growers of sugarcane and, therefore, only purchase tax was payable on such transactions. Though the said scheme was to remain in force for a period of five years, the Government decided to introduce a new scheme of sales tax benefits in lieu of the said tax exemption/loan scheme. The cash subsidy scheme was retained as it was. Under this scheme all eligible industrial units became entitled to the benefit of sales tax exemption incentive, whereas under the 1970 Scheme, this benefit was available only to SSI units. The cash subsidy scheme was retained as it was. Under this scheme all eligible industrial units became entitled to the benefit of sales tax exemption incentive, whereas under the 1970 Scheme, this benefit was available only to SSI units. Another change, which the Government made this time, was whereas this benefit was available for purchase of machinery and equipment also, under the 1980 Scheme this benefit was withdrawn. Thus, with slight modifications, the sales tax exemption incentive was continued by the Government. In view of the limited duration of the earlier schemes, and the modifications made by the 1980 Scheme, a fresh notification under section 49 of the Act was issued by the Government on 5th February, 1981, adding entry No. 118 in the Schedule to the parent notification of 1970. By that notification also, the Government exempted specified manufacturers, i.e., persons establishing new industries, from payment of whole of purchase tax under section 15 of the Act in respect of their purchases of raw materials, consumable stores or packing materials and processing materials from a person, who was not a registered dealer. Though it is not strictly relevant for our purpose, it may be stated that, on expiry of the period of the 1980 Scheme, the Government announced another scheme, by its resolution dated 6th May, 1986, known as "Sales Tax Incentive Scheme for Industries, 1986". It became effective from 1st April, 1986 and was to remain in force for a period of 5 years. Under that scheme also, sales tax exemption was granted almost in the same terms as in the 1980 Scheme. Again, the Government had issued a notification under section 49 of the Act with a view to make the said resolution effective and added entry 175 in the parent notification, exempting purchases of raw materials, processing materials and consumable stores of packing materials from a person, who was not a registered dealer, from whole of purchase tax under section 15 of the Act. 20th January, 1992 : From what is stated above, it becomes clear that the Government, at all materials times, thought that the representation, which was made under the different schemes with respect to exemption from sales tax, was only in regard to payment of purchase tax payable under section 15 of the Act. 20th January, 1992 : From what is stated above, it becomes clear that the Government, at all materials times, thought that the representation, which was made under the different schemes with respect to exemption from sales tax, was only in regard to payment of purchase tax payable under section 15 of the Act. Till 1985, no entrepreneur had claimed any benefit of exemption from payment of purchase tax under section 18 of the Act. Thus, till then, the persons engaged in the khandsari industry also believed the representation to be that the benefit, which was available in that behalf, was only in respect of payment of tax under section 15 of the Act. None of the petitioners had sought for any clarification between 27th August, 1980 and 5th February, 1981, as to whether any benefit of exemption was to be available from payment of purchase tax. Even after issuance of the notification dated 5th February, 1981, no enquiry was made as to why similar notification for exemption from payment of purchase tax under section 18 was not issued by the Government. So far as the petitioners in Special Civil Application No. 2033 of 1985 are concerned, it is significant to note that the firm was constituted on 21st July, 1980, i.e., before the passing of the resolution dated 27th August, 1980. Therefore, if at all the it was constituted with a view to set up an industry, induced by the declaration of any policy by the Government, then, that must be according to the policy declared by the Government Resolution dated 22nd December, 1977. Under that resolution, the only benefit, which was declared by the Government, if the resolutions dated 22nd December, 1977 and 27th August, 1980, are read together, was that exemption from payment of purchase tax was available only with respect to the tax payable under section 15 of the Act. So far as the other two petitioners are concerned, they have started commercial production after the issuance of notification dated 5th February, 1981. For the reasons stated above, we are of the view that neither by resolution dated 22nd December, 1977 nor by its resolution dated 27th August, 1980, the Government had made a representation or held out a promise that exemption from payment of purchase tax under section 18 of the Act was also to be available for purchases of raw materials, i.e., sugarcane. We are also of the view that the petitioners did not understand the representation or promise in that manner and altered their position upon that basis. It is, therefore, not necessary to consider the other contentions raised by the petitioners, namely, what is the effect of granting of eligibility certificate and that by issuing a notification of exemption from payment of tax under section 15 only and by not issuing a similar notification of exemption from payment of tax under section 18, the Government can be said to have backed out from its promise. In the result, these petitions fail. Rule issued in each of these petitions is discharged, with no order as to costs. Interim relief stands vacated. Writ petitions dismissed.