Judgment ( 1 ) THIS batch of appeals has been preferred by small-scale industrial units which carry on the business of manufacturing edible oils in the State of jammu and Kashmir. The manufacture of edible oils was exempted from payment of sales tax under Exemption Notification No. SRO-93 dated 27-3-1991 which granted exemption to small-scale industrial units for the period 1-7-1990 onwards from payment of general sales tax under the Jammu and Kashmir General Sales Tax Act, 1962, provided that the goods manufactured were not of the kind specified in Annexure a to the notification. Annexure a consisted of two parts. The first contained details of the period for which exemption was to be granted and the extent of exemption. Thus 100% exemption was granted up to 31-3-1995, 50% till 31-3-1998 and 25% till 31-3-2000. The second part specified the excluded industries (which is referred to hereinafter as "the Negative List") which did not include edible oils. Consequently, the appellants before us were entitled to exemption under Notification No. SRO-93 of 1991. ( 2 ) ON 19-1-1995 a government order was issued, being GO No. 10 of 1995, which enunciated the States policy in respect of new units in the tiny/ small/medium/large-scale sector which would be established after the announcement of the new policy. Existing units were also given the option to continue with the package of incentive to the extent applicable for the remaining period of entitlement. The package of incentives included para 7 which reads as follows: "7. GST/cst/additional toll tax on SSI Units, medium and largescale units (i) The purchase of raw materials by small-scale units shall be exempted from general sales tax except for the items which are on the negative List. (ii) GST exemption is also available to small-scale units on sale of finished goods till 31-3-2000 except for the items which are on the negative List. (iii) No GST would be charged on sale of finished goods manufactured by SSI Units. This concession is also available up to 31-3-2000. (vii) negative List referred to in the above paras may be altered by the Government in the Industries and Commerce Department in consultation with the Finance Department. " ( 3 ) IN other words instead of granting exemption at reducing percentages till 31-3-2000, the policy was to grant 100% exemption till that date. (vii) negative List referred to in the above paras may be altered by the Government in the Industries and Commerce Department in consultation with the Finance Department. " ( 3 ) IN other words instead of granting exemption at reducing percentages till 31-3-2000, the policy was to grant 100% exemption till that date. Para 19 of the government order, however, provided that the policy would come into force from the date of a notification. ( 4 ) THE relevant notification was issued on 4-4-1995. The notification, which is numbered as SRO-87, gave effect to the government policy by directing that for the Schedule forming the first part of Annexure A to notification No. SRO-93 dated 27-3-1991, the following would be substituted, namely, ( 5 ) THE notification was to come into force with effect from 1-4-1995. ( 6 ) IN the meanwhile, according to the appellants they had set up their industrial units on the basis of the government policy. They claimed for and were granted 100% exemption on the edible oils manufactured by them. Their grievance is that this benefit which should have continued at least up to 2000 was suddenly withdrawn on 31-3-1997 with effect from 1-3-1997 by notification No. SRO-122. The exemption was withdrawn by amending notification No. SRO-93 and adding edible oils to the Negative List of industries in Annexure a. The reason given by the Government for including edible oils in the Negative List and denying further exemption to this commodity was a decision of this Court in Shree Mahavir Oil Mills v. State of Jandk. ( 7 ) THE appellants filed writ petitions in the High Court challenging the withdrawal of the exemption basically on two grounds (7) that the State was bound by the principle of promissory estoppel by the government order in 1995 granting exemption from general sales tax uptil 2000 and (2) that the reason given by the State Government for issuing Notification No. SRO-122 was incorrect in the sense that the decision in Shree Mahavir Oil Mills had been wrongly construed and that the law on the subject as laid down in Video electronics (P) Ltd. v. State of Punjab as considered in Shree Mahavir Oil mills allowed the State to grant special benefit to new industrial units within the State by way of exemption from payment of sales tax. ( 8 ) WE are not prepared to hold that the government policy by itself could give rise to any promissory estoppel in favour of the appellants against the respondents since the policy itself made it absolutely clear that it would come into effect only on appropriate notification being issued. The notification was issued in exercise of the admitted powers of the State Government under the state General Sales Tax Act. The State Government having power and competence to grant the exemption was equally empowered to withdraw it. As we have also noticed there was nothing either in the notification or in the policy which provided that the Negative List would not be amended or altered. On the contrary clause (vii) of para 7 to GO No. 10 of 1995 expressly reserved the Governments right to amend the Negative List. The right if any of the appellants was a precarious one and could not found a claim for promissory estoppel. ( 9 ) AS far as the second submission of the appellants is concerned, Shree mahavir Oil Mills set aside Notification No. SRO-93 of 1991. It did so on the basis that the State was incompetent to grant relief in respect of edible oils industries. It was said that the action of the State Government in granting total exemption in favour of small-scale industries in Jammu and Kashmir producing edible oil was unconstitutional, particularly being contrary to Articles 301 and 304 thereof and was unsustainable in law. There can be no manner of doubt that this Court in shree Mahavir Oil Mills had expressly and in no uncertain terms set aside notification No. SRO-93. The benefit which was granted to the appellants was also under this very notification. As we have observed, the edible oil industries were entitled to the benefit of Notification No. SRO-93 since edible oil was not an industry mentioned in the Negative List. The State government, in view of the decision of this Court had no other option but to place edible oils in the Negative List. The questions whether Shree Mahavir oil Mills has been rightly decided or not and whether it is in conflict with the principles enunciated in Video Electronics are moot. But while the decision stands, the State Government is bound to comply with it. The questions whether Shree Mahavir oil Mills has been rightly decided or not and whether it is in conflict with the principles enunciated in Video Electronics are moot. But while the decision stands, the State Government is bound to comply with it. ( 10 ) IN the circumstances of the case, we dismiss the appeals but without any order as to costs.