Vegetable oil definition excludes solvent-extracted oil from oil cakes, leaving no cess liability under the statute.

Oil extracted from oil cakes by solvent extraction was held not to fall within the statutory definition of "vegetable oil" for cess purposes. The Bombay High Court read "oil-bearing material of plant origin" in its popular and commercial sense, requiring a direct nexus with the plant source rather than a remote or derivative connection. Oil cakes were treated as a distinct commercial by-product after initial extraction, and the further technical process used to recover oil from them took it outside the definition. As a result, no cess was leviable on such oil under the Vegetable Oils Cess Act, 1983.

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Issues: Whether oil extracted from oil cakes by the solvent extraction process is covered by the expression "vegetable oil" under the statutory definition and is therefore liable to cess under the Vegetable Oils Cess Act, 1983.

Analysis: The relevant definition of "vegetable oil" was construed as covering oil produced from oilseeds or from other oil-bearing material of plant origin, while excluding oil subjected to further processing after recovery. In the context of a taxing statute, the word "origin" was held to bear its popular and commercial sense, requiring a direct nexus between the plant and the oil-bearing material, not a remote or derivative connection. Oil cakes were treated as a distinct commercial commodity, being by-products of oilseeds after extraction, and the oil could be obtained from them only through a skilled technical process of solvent extraction. On that basis, oil derived from oil cakes was held not to be oil from oil-bearing material of plant origin within the statutory definition.

Conclusion: Oil extracted from oil cakes by solvent extraction is not "vegetable oil" within the meaning of the statutory definition and no cess is leviable on such oil under Section 3 of the Vegetable Oils Cess Act, 1983.

Ratio Decidendi: In a taxing statute, "plant origin" in the definition of vegetable oil requires a direct and popular-commercial nexus with the plant, and oil obtained from oil cakes by a further technical process is outside that definition.

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