Special law prevails over general cess law: coconut oil from copra was held outside the later vegetable oil cess regime.

Coconut oil extracted from copra is not liable to cess under the Vegetable Oil Cess Act, 1983 because the later general definition of vegetable oil could not override the earlier special statutory scheme for coconut, copra and coconut oil products. The special legislation enacted in 1979 was treated as continuing to govern those commodities, and Parliament had not clearly expressed any intention to bring them within the 1983 cess regime. A later general taxing enactment will not be construed to cover a commodity already regulated by a prior special law unless that intention is stated expressly.

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Issues: Whether coconut oil extracted from copra is liable to cess under the Vegetable Oil Cess Act, 1983.

Analysis: The relevant enactments were read together to determine whether coconut and copra had been taken out of the earlier cess regime and brought within the later legislation. The 1979 enactments were found to deal specifically with coconut, copra, and coconut oil products, whereas the 1983 enactments defined vegetable oil with reference to oil produced from oilseeds or other oil-bearing material of plant origin. The Court held that the general definition in the 1983 legislation could not be stretched so as to nullify the special scheme already created by the Coconut Development Board Act, 1979 and the Copra Cess Act, 1979. Parliament having not expressly included coconut and copra within the later enactments, the earlier special exclusion continued to govern.

Conclusion: Coconut oil extracted from copra is not liable to cess under the Vegetable Oil Cess Act, 1983.

Ratio Decidendi: A later general taxing enactment cannot be construed to include a commodity already governed by a prior special statutory scheme unless the legislature clearly manifests that intention; special provisions concerning coconut and copra prevail over the general definition of vegetable oil.

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