Judgment Dalip Singh, J.- The petitioner company has filed this writ petition with prayer that the respondent State of Rajasthan and the Rajasthan Financial Corporation and its officers be directed by means of a writ to disburse the subsidy amounting to Rs. 3,00,000/-as mentioned in the letter (Annexure-1) issued by the Respondent No. 2 dated 6/10.02.1986. 2. The case of the petitioner as mentioned in the writ petition and more particularly in Para No. 4 is that after incorporation of the petitioner company, the petitioner company has submitted a detailed project report for the manufacture of asbestos cements pressure and non-pressure pipes and consequent upon the sanction of this scheme an application for the sanction of loan to the Respondent No. 2 was also made and the same was sanctioned vide Annexure-1 dated 6/10.02.1986. The petitioner company in terms of letter Annexure-1 dated 6/10/.02.1986 applied for the disbursement of the amount of subsidy of Rs. 3,00,000/-as mentioned in the said letter. The copies of the applications are Annexures-2 and 3 on the record. It has further been submitted that a reply was received on 112.1986 from the Respondent No. 2 (Annexure-4) wherein it has been stated by the respondent with reference to the application for grant of subsidy that the petitioner company being a cement based unit is not eligible for the State subsidy as per the rules as such, the matter stands closed. 3. After the receipt of the aforesaid letter, the petitioner company entered into further correspondence and representation, but the same reply was given to the petitioner company that the petitioner industry being a cement based unit the company is not eligible for the “State ” subsidy. The petitioner in his representation had sought to make out a case at par that an industrial unit situated at Bhilwara, M/s Shree Pipes Limited has submitted that the said unit at Bhilwara which was also manufacturing a similar product as the petitioner and the said industry at Bhilwara had being given the subsidy as per policy and hence on a parity it was submitted by the petitioner that the subsidy should be given to the petitioner company also. 4. The respondent sent a reply Annexure-6 dated 20.01.1987 that the units manufacturing of PCC Poles etc. being cement based units were not entitled to the benefit of subsidy in accordance with the scheme of State Government. 4. The respondent sent a reply Annexure-6 dated 20.01.1987 that the units manufacturing of PCC Poles etc. being cement based units were not entitled to the benefit of subsidy in accordance with the scheme of State Government. So far as the unit at Bhilwara is concerned the same is being allowed subsidy under the scheme framed by the Central Government as distinct from the State Government from the subsidy is being claimed by the petitioner company. So far as the scheme of the State Government is concerned cement based units are ineligible for the grant of subsidy. 5. It is against the refusal by the State Government and the Respondent No. 2 to allow the subsidy to the petitioner that the petitioner has filed the present writ petition. 6. The submissions of the learned Counsel is that at the time of sanction of loan vide Annexure-1 the petitioner had allowed an amount benefit of Rs. 3 lacs as subsidy and the respondents have been re-attracted from their assurance and they cannot be allowed to re-attract the same as they are estoppel from doing so, as it was a promise held out to the petitioner by the respondent. 7. To the aforesaid submissions of the learned Counsel for the petitioner and the learned Counsel appearing on behalf of the respondent Shri Arjun Singh has drawn my attention to the contents of Annexure-1 itself the order of sanction wherein Para 5 it was been specifically mentioned as under:- “5 you are also advised to apply for grant of Central/ State Subsidy, if not already done, in case your unit is eligible for the same.” It is on the basis of the aforesaid that the learned Counsel for the respondent has submitted that what has been stated in Annexure-1 was subject to the unit being eligible for the grant of subsidy. He has further submitted while drawing the attention to Annexure R-1 the policy of the State Government wherein the list of Industries who are ineligible for the grant of subsidy the item 12th of the enclosed list has been mentioned as “PCC Ploes and cement based unit”. He has further drawn attention of the Court to the affidavit filed by Shri Laxmidutt Purohit who was officer-in-charge stating therein that cement or cement product based units are not eligible for the subsidy in accordance with the policy of the State for State subsidy. He has further drawn attention of the Court to the affidavit filed by Shri Laxmidutt Purohit who was officer-in-charge stating therein that cement or cement product based units are not eligible for the subsidy in accordance with the policy of the State for State subsidy. He has further submitted that the petitioner unit was manufacturing AC Pressure Pipes for which the raw material is cement hence in the light of the aforesaid it has been submitted that the petitioner unit is not entitled to the grant of subsidy the same is a cement based unit. 8. The learned Counsel for the petitioner also submitted that the main component for the manufacture of AC Pressure Pipes which are being manufactured by the petitioner unit is asbestos and cement is one of component as such it cannot be held that the petitioner unit is a cement based unit. He has relied upon a decision filed as Annuexre-10 of the Additional Commissioner Commercial Taxes Rajasthan, Jaipur wherein it was held that the Asbestos AC Pressure Pipes are distinct product covered by the Entry 115 of the notification dated 08.03.1988 issued under the Rajasthan Sales Tax Act as opposed to articles of cement covered by Entry 95 of the said notification. The learned Counsel, therefore, submitted that Asbestos products which though have a component of cement cannot be term to be a cement product. It is, therefore, being submitted that in view of the aforesaid it cannot be held that the petitioner unit is a cement based unit. 9. I have considered the rival submissions. So far as the plea of Promissory stopple is concerned suffice it to say that in Annexure-1 which was issued to the petitioner mentioned an amount of Rs. 3 lacs as subsidy, however, the same was made subject to the fact in case the unit is eligible for the same. Hence, there was a condition attached and it cannot be said that the offer was un-conditional or in-equivocal. In the facts and circumstances what has been mentioned in Para 5 of the letter of sanction Annexure-1, the same cannot be construed to constitute a promissory estople so as to bind the respondent to allow the petitioner to avail subsidy at all costs. 10. In the facts and circumstances what has been mentioned in Para 5 of the letter of sanction Annexure-1, the same cannot be construed to constitute a promissory estople so as to bind the respondent to allow the petitioner to avail subsidy at all costs. 10. The principle question which is required to be is adjudicated is whether the petitioner unit in terms of the policy Annexure R-1 is eligible for availing of subsidy in view of the entry at Sr. No. 12 in the list of ineligible industries. It is not in dispute that the petitioner industry is a manufacturer of AC Pressure Pipes and in which cement is used for the manufacture of the same through the cement is used alongwith asbestos. The entry in the list at Sr. No. 12 provides that industries which are cement based units are in eligible for availing subsidy. In the facts and circumstances it cannot be disputed that the petitioner unit is manufactured AC Pressure Pipes and utilize cement for the manufacture of the same. In view of the aforesaid it cannot be said that the petitioner unit is not “a cement based unit”. The entry in the list is wide enough to cover the industries which are using the cement as raw material and consequently it would be in eligible for the grant of or availing of the benefit of the subsidy in terms of the scheme of the State Government Annexure R-1. 11. So far as the argument of the learned Counsel for the petitioner based upon the Judgment Annexure-10 is concerned that AC Pressure Pipes have not been held to be articles made from cement is concerned under the notification dated 08.03.1988 there are three separate entries first Entry No. 74 which relates to all types of sanitary goods and fitting and all types of pipes and fitting. Then second Entry No. 95 relates to articles made of cement and third Entry No. 115 relates to products of all sorts of asbestos including flat and corrugated sheets. Suffice to say that under the scheme of the notification prescribing to the rates for different item for the purpose of the sales tax the entries have been dealt with separately. Then second Entry No. 95 relates to articles made of cement and third Entry No. 115 relates to products of all sorts of asbestos including flat and corrugated sheets. Suffice to say that under the scheme of the notification prescribing to the rates for different item for the purpose of the sales tax the entries have been dealt with separately. In order to bring about clarity the legislature has prescribed the different rates of tax for various goods and they have been categorized as such in the instant case Item No. 12 in the list of ineligible units is a single for availing subsidy irrespective of the fact whether cement is the sole or an allied component. In that view of the matter to my mind the Judgment Annexure-10 does not help the petitioners case. The legislature in its wisdom has considered to sub-categorize various products for tax purposes but in the instant case it has not done so far the availing of subsidy. Thus, the Entry No. 12 of the list in Annexure R-1 has to be read in its plaint meaning and not in the light of the entries under the Sales Tax Act. 12. It was contended by the learned Counsel for the petitioner that in the case of M/s. Shree Pipes Unit situated at Bhilwara manufacturing AC Pressure Pipes the said unit at Bhilwara was permitted to avail the benefit of subsidy where as the petitioner unit which is also manufacturing the same product has been denied the benefit. The learned Counsel for there respondent Shri Arjun Singh alongwith Deputy Government Advocate has drawn my attention to Annexure-6, the reply sent to the petitioner on his representation claiming parity with the unit at Bhilwara where in the respondents have clearly stated that the unit at Bhilwara was availing the benefit of subsidy under the scheme of the Central Government and not Annexure R-1 the scheme framed by the State Government. It is no a case of the petitioner that the State had in any way allowed any cement based unit similar to the petitioner to avail the benefit of subsidy under the State scheme Annexure R-1. The availing of subsidy by the Bhilwara Unit under the scheme of the Central Government cannot be ground for discrimination by the State Government under its scheme as the two are separate and distinct. 13. The availing of subsidy by the Bhilwara Unit under the scheme of the Central Government cannot be ground for discrimination by the State Government under its scheme as the two are separate and distinct. 13. In view of the aforesaid this writ petition deserves to be dismissed. The same is dismissed. The interim order passed by this Court on 211.1990 is vacated. 14. There shall be no order as to costs.