Rice bran oil outside vegetable oil levy because the statutory definition does not cover a rice by-product as an oilseed material.

Rice bran oil is not covered by the cess levy on vegetable oils because the incorporated statutory definition requires oil produced from oilseeds or other oil-bearing material of plant origin containing glycerides. Rice bran is only a by-product of rice, not a seed capable of germination, and it does not answer to the common or commercial meaning of an oilseed or qualifying plant-origin material. The levy under the Vegetable Oils Cess Act, 1983 therefore does not extend to rice bran oil, and no cess is chargeable on it.

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Issues: Whether rice bran oil is a vegetable oil liable to cess under the Vegetable Oils Cess Act, 1983.

Analysis: Section 3 of the Vegetable Oils Cess Act, 1983 levies cess on vegetable oils, and Section 2(2) incorporates the meaning assigned to undefined expressions in the National Oilseeds and Vegetable Oils Development Board Act, 1983. Under Section 3(h) of that Act, vegetable oil means oil produced from oilseeds or any other oil-bearing material of plant origin containing glycerides, excluding oil subjected to processing after recovery. Rice bran is only a by-product of rice and not a seed capable of germination. It is not, in common or commercial understanding, an oilseed, nor can it be treated as oil-bearing material of plant origin for the purposes of the levy.

Conclusion: Rice bran oil is not vegetable oil for purposes of the Vegetable Oils Cess Act, 1983, and no cess was leviable.

Ratio Decidendi: Where a taxing statute incorporates an undefined expression from another enactment, the incorporated definition governs, but the commodity must still fall within the statutory words in their proper commercial and legal sense before the levy can be imposed.

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