As per case facts, the Petitioner company, an approved SEZ developer, was promised exemption from local taxes including octroi by the State Government's policy. Despite this, the Pune Municipal Corporation ... (PMC) collected octroi from the Petitioner, and the State Government failed to ensure the promised exemption by amending the relevant rules or compensating the PMC. The Petitioner sought refund of the octroi paid. The question arose whether the State Government was bound by its policy to grant octroi exemption to the Petitioner and, if so, who was liable for the refund given the PMC's inability to refund without statutory amendment. Finally, the court held that the State Government was bound to fulfill its policy and the promise made. While PMC was not liable to refund due to the lack of rule modification, the State Government was directed to refund the octroi to the Petitioner with interest, based on the principle of promissory estoppel.