delivered the opinion of the Court. Barnes, J., dissents. Dissenting opinion at page 419 infra.
*414In the summer of 1964, Harris Used Car Co., Inc. (Harris) purchased from Edward G. Lavender a tract of approximately 3 acres on Evergreen Road about 100 feet west of Route 3 in Gambrills, Maryland, in the Fourth Election District of Anne Arundel County (the County). On 24 April 1964, Lavender, acting in Harris' behalf, had obtained from a County zoning official an Occupancy Certificate authorizing the tract, which was zoned agricultural, to be used as a “Used Car lot and Salvage auto garage.” Attached to the application for the certificate was the sworn statement of Lavender and three residents of the area that “* * * the Garage on Evergreen Road in Gambrills, Maryland, owned by Edward G. Lavender, has been used as a garage continuously since 1942.”
Relying on the permit, Harris moved some vehicles from Baltimore and commenced the operation of an automobile junk yard on the property. On 17 December 1965, the County notified Harris that it was voiding the Occupancy Certificate because it had been issued in error. No appeal was taken to the County’s Board of Appeals, but after the time for appeal had expired, Harris requested the County’s Office of Planning and Zoning “* * * to review this matter with the hope of reissuing the Certificate.”
Six months later, in July of 1966, the County filed a bill in equity against Harris, its president and the manager of the junk yard seeking an injunction forbidding the use of the property for a “used car, salvage auto garage, and junk business * * The case finally came on for trial in October of 1968, and from a decree entered on 6 March 1969, enjoining Harris from using the property for any purposes not permitted in an agricultural zone and requiring the removal of “all wrecked and salvage vehicles and parts and used cars,” Harris has appealed.
Harris raises two questions: (i) Does it have a valid non-conforming use? (ii) Assuming that a non-conform*415ing use has not been established, is the County estopped from revoking the Occupancy Certificate by delay?
(i)
The trial below extended over two days, during which the court heard fourteen witnesses. The testimony was sometimes conflicting, often indecisive and discursive. At the conclusion of the hearings the chancellor (Melvin, J.) filed an opinion in which he found the following facts:
“1. The defendant corporation purchased the property (3.1 acres) in August, 1964.
“2. The former owner, Edward T. Lavender, conducted an extensive auto junk and salvage business on the property from about 1940 until 1945. Thereafter, pursuant to a federal order, Lavender disposed of practically all the used and junked cars and discontinued the business in 1946 or 1947. Although there may have been two or three abandoned vehicles on the property at that time, the property was no longer used by Lavender as an auto junk yard or used car lot.
“3. Between 1945 and 1947 a quonset hut and cinder block building were erected on the property in which Lavender stored some old auto parts.
“4. For a two year period between 1946 and 1948 Lavender rented the cinder block building to Laurence W. Chaney who used the building to maintain his vehicular equipment used in connection with his lumber business. Chaney, a defense witness, testified that during this two year period, Lavender conducted ‘no business’ on the property.
“5. For another one or two year period prior to 1961, the cinder block building was leased to a sewer cont [r] acting company which used it to store and maintain its vehicular equipment.
“6. In 1961 the cinder block building ‘and the ground under it’ were rented to Mitchell Harris *416[who was in no way connected with the appellant Harris] who said he used the building until March of 1964 only to repair his own vehicles.
In March and April 1964 he used it to ‘work on other people’s cars’ also. He also said that during the three year period, 1961-1964, Lavender conducted no business on the property.
“7. On April 24,1964, a county zoning official issued a zoning certificate of occupancy to the corporate defendant [Harris] purporting to authorize use of the property as a ‘used car lot and salvage auto garage.’
“8. On December 17, 1965, this certificate of occupancy was revoked by the Office of Planning and Zoning and no appeal was taken from this administrative action by the defendants.”
We are mindful that Rule 886 a provides that when a case has been tried below without a jury the judgment of the lower court will not be set aside on the evidence unless it is clearly erroneous.
There is substantial evidence in the record to support the chancellor’s conclusion that Lavender had abandoned his use of the property as an automobile junk yard or used car lot by 1947, which was several years prior to the effective date of the first comprehensive zoning ordinance for the Fourth Election District, within which the property lies, on 25 July 1950. We have reviewed this finding, as we must, in the light most favorable to the party prevailing below, Space Aero Products Co. v. R. E. Darling Co., 238 Md. 93, 105, 208 A. 2d 74, 699 (1965) and on the record before us cannot hold that the finding was erroneous much less clearly erroneous.
Sec. 35-10 of the Zoning Ordinance of Anne Arundel County, effective 1 July 1952, provides:
“A lawful nonconforming use existing on the effective date of the adoption of this chapter may continue; provided, however, upon any change from such nonconforming use to another *417nonconforming use in a more restricted classification, or to a conforming use, or in the case of the abandonment of such nonconforming use for the period of one year, the right to continue such original nonconforming use shall cease. A nonconforming use may change to a use permitted in the most restricted district in which such existing nonconforming use is permitted under this chapter or to a more restricted classification.” Zoning Ordinance of Anne Arundel County (1958).
In its brief, Harris asserts that the date on which zoning of the area first became effective was 2 December 1947, citing Laque v. State, 207 Md. 242, 249, 113 A. 2d 893 (1955). We are not persuaded by this argument, because the property in Laque was located in the Fifth Election District, where the ordinance before the Court had first been made applicable to that District by a resolution of the Board of County Commissioners adopted on 2 December 1947.
As we see this case, the issue is not necessarily whether the non-conforming use was abandoned, compare Landay v. Bd. of Zoning Appeals, 173 Md. 460, 196 A. 293, 114 A.L.R. 984 (1938) with Dorman v. Mayor & C.C. of Baltimore, 187 Md. 678, 51 A. 2d 658 (1947) but rather whether the property was being used for any non-agricultural purpose on the date the first zoning ordinance became effective, whether it be 25 July 1950, as the court assumed, relying on Laque v. State, supra, or 1 July 1952, when the first comprehensive ordinance became effective for the entire County, as the County contended, Stieff v. Collins, 237 Md. 601, 207 A. 2d 489 (1965). There was evidence to support a finding that no such use existed on either of these dates. A mere intention to use is not enough to establish a non-conforming use. Chayt v. Bd. of Zoning Appeals, 177 Md. 426, 9 A. 2d 747 (1939) ; Beyer v. Mayor & C.C. of Baltimore, 182 Md. 444, 34 A. 2d 765 (1943).
*418(ii)
Harris would have us hold that the County was es-topped from revoking the Occupancy Certificate because while a permit illegally, erroneously or mistakenly issued vests no rights in the holder, Mayor & C.C. of Baltimore v. Shapiro, 187 Md. 628, 634, 51 A. 2d 273 (1947), in the absence of fraud, substantial expenditures made in reliance on the permit may confer certain rights. Town of Berwyn Heights v. Rogers, 228 Md. 271, 179 A. 2d 712 (1962) ; 2 Metzenbaum, Law of Zoning Ch. X-f-1 (2d Ed. 1955) at 1167; 2 Rathkopf, The Law of Zoning and Planning, Ch. 57-6 § 3 (3d Ed. 1966) ; 8 McQuillin, Municipal Corporations § 25.95 (3d Ed. 1965) at 272.
Assuming the correctness of Harris’ contention, the record provides no hook on which Harris can hang its hopes. Only two oblique hints appear, one in the testimony of Burgone, the manager of Harris’ yard, when he described a meeting with a County zoning official:
“I said that we had spent several thousands of dollars on — after we got the permit. We had the permit. We was in business in Baltimore City. We disposed of our business and come down here and invested thousands of dollars 1 and I would like to know what was happening.”
The second appeared, curiously enough, when Lavender was being cross examined by the County’s attorney:
“Q41 And I imagine that this was a condition of your contract with Harris that he would be able to operate the property as a Used car and salvage business when he bought it?
“A No, I told them that I used to run a junk yard there and he asked me, ‘did you do any burning,’ and I said, ‘Yes, I did *419burning.’ And that was all. Now whether he [in] ferred that I sold it to him as a going business or not I don’t know.
“Q42 What I am getting at is you know the property is zoned agricultural ?
“A Yes, sir, it was zoned agricultural.
“Q43 There’s quite a difference between the price [of] agricultural land and commercially zoned land?
“A Yes.”
Later Lavender admitted that Harris did not settle for the property until the Occupancy Certificate had been issued.
It is quite remarkable that there is not a shred of evidence of how many “thousands of dollars” Harris spent, or on what they were spent, and neither an intimation of the price Harris paid for the property, nor an opinion of its value if it be limited to agricultural use. The proof before us fell far short, under our decisions, of sustaining Harris’ claim of a vested right. In Ross v. Montgomery County, 252 Md. 497, 250 A. 2d 635 (1969), $56,000 had been spent in architect’s fees in reliance on a building permit which was nullified by a zoning change; in Mayor & C.C. of Baltimore v. Shapiro, supra, 187 Md. at 634, nine cars had been towed to a lot and dismantled; and in Board of County Comm’rs of Anne Arundel County v. Snyder, 186 Md. 342, 46 A. 2d 689 (1946), “several thousand dollars” had been spent on grading and landscaping. In all three cases, we held that the expenditure or change in position raised no estoppel. To rely on estoppel, Harris would have had to show substantial prejudice. This he has failed to do.
Decree affirmed, costs to be paid by appellants.
. At argument, Harris’ counsel said that expense had been incurred in moving an unspecified number of ears from Baltimore to Gambrills.