Sal Seed Oil and Sal Seed Fat treated as the same input for money credit under the notifications.

The notifications allowing money credit for Sal Seed Fat were construed to cover Sal Seed Oil as well, because the two were treated as the same product in different physical states. Technical material and precedent showed that the distinction between oil and fat was one of temperature and solidity, not chemical identity, and liquid form was not essential to vegetable oil. The broader object of the notifications was to encourage use of Sal seed oil or fat in manufacture, so a narrow reading would undermine that purpose. On that basis, Sal Seed Oil fell within the notified eligible input for money credit.

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Issues: Whether Sal Seed Oil could be treated as Sal Seed Fat for the purpose of availing money credit under the relevant notifications.

Analysis: The Notifications granting money credit referred to Sal Seed Fat as an eligible input. The appellant established that Sal Seed Oil and Sal Seed Fat are the same product in different physical states, the distinction being one of temperature and solidity rather than chemical identity. The accepted technical meaning of fats and oils, the material placed from standard works, and the cited precedents showed that liquid state is not an essential characteristic of vegetable oil. The object of the Notification was to encourage the use of Sal Seed oil or fat in manufacture of vegetable product, and a narrow construction would defeat that purpose.

Conclusion: Sal Seed Oil was held to fall within Sal Seed Fat for the purpose of the Notifications, and the assessee was entitled to the money credit.

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