Vegetable oil cess attaches at extraction, and later refining of soyabean oil does not remove the levy.

Vegetable oil cess under the Vegetable Oil Cess Act, 1983 is attracted at the stage of extraction of vegetable oil. Soyabean oil falls within the statutory meaning of vegetable oil through the incorporated definition in the National Oil Seeds and Vegetable Oil Development Board Act, 1983. Because the levy attaches when the oil is produced from oil-bearing material, later refining or other post-extraction processing does not create a fresh levy or exempt the oil from cess. The stated result is that the cess remained validly chargeable at extraction, and subsequent processing did not alter liability.

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Issues: Whether vegetable oil cess was leviable on soyabean oil at the stage of extraction, and whether the oil became exempt merely because it was later subjected to refining or other processing.

Analysis: Cess under Section 3 of the Vegetable Oil Cess Act, 1983 is attracted by the extraction of vegetable oil. The expression "vegetable oil" is not independently defined in that Act, and Section 2(2) incorporates the meaning assigned under the National Oil Seeds and Vegetable Oil Development Board Act, 1983. Under Section 3(b) of that Act, vegetable oil means oil produced from oil seeds or other plant-origin oil-bearing material, but excludes oil subjected to processing after recovery. Soyabean oil falls within that definition. The levy therefore attaches when the oil is extracted, and later processing does not create a fresh liability.

Conclusion: The cess was validly leviable on the soyabean oil at the extraction stage, and subsequent refining did not exempt it from the levy; the appeal failed.

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