In Union of India v. Unicorn Industries, the withdrawal of the exemption to the pan masala with tobacco and pan masala sans tobacco in the State of Assam was under challenge before the Supreme Court.
The Supreme Court held that by invoking the doctrine of promissory estoppel, the Union of India cannot be estopped from withdrawing the exemption from payment of Excise Duty in respect of certain products, which exemption is granted by an earlier notification; when the Union of India finds that such a withdrawal is necessary in the public interest. The bench said that the larger public interest would outweigh an individual loss, if any.
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