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SC held that crude degummed soyabean oil is a manufactured product distinct from its agricultural origin, not an agricultural product. The administrative circular No. 10/2004 cannot legally expand the exclusionary clause of notification No. 53/2003. The manufacturing process transforms soyabean into a new commodity with different characteristics, thereby enabling the appellant to claim duty-free credit entitlement. The court rejected the HC's finding that crude degummed soyabean oil remains an agricultural product, and allowed the appeal, granting the appellant benefits under the original notification.
SC held that crude degummed soyabean oil is a manufactured product distinct from its agricultural origin, not an agricultural product. The administrative circular No. 10/2004 cannot legally expand the exclusionary clause of notification No. 53/2003. The manufacturing process transforms soyabean into a new commodity with different characteristics, thereby enabling the appellant to claim duty-free credit entitlement. The court rejected the HC's finding that crude degummed soyabean oil remains an agricultural product, and allowed the appeal, granting the appellant benefits under the original notification.
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