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The petitioner challenged the imposition of entry tax on crude soybean oil brought into Madhya Pradesh for manufacturing/refining soybean refined oil under the MPCT Act and Entry Tax Act. The petitioner argued that if refining crude soybean oil is considered manufacturing, then crude oil being a raw material would be exempt. The court held that refining crude oil into refined soybean oil constitutes a manufacturing process, resulting in a new consumable product. Despite the notification excluding refining from manufacturing under the MPCT Act, entry tax is leviable under the Entry Tax Act for consumption/use or sale in the local area. The court dismissed the petitions, upholding the tax authorities' orders imposing entry tax on crude soybean oil brought for refining into refined soybean oil.