1992 (2) TMI 359

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....ification issued by the Commissioner of Commercial Taxes stating that the groundnut oil brought into a local area for refining is taxable under entry 16B up to March 31, 1987, has approached this Court. Pursuant to this clarification, in the course of the assessment, a pre-assessment notice is issued to the petitioner relying upon the aforesaid clarification. 2.. Though normally this Court coul....

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....ected to certain process like hydrogenation continues to be oil, arose for consideration and the Supreme Court held that it does not give rise to a new commodity at all and therefore tax was not attracted to that particular goods. The contention advanced on behalf of the assessee in that case is that the hydrogenated groundnut oil was no less groundnut oil than either refined or unrefined oil and ....

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....as oil or for any purpose for which oil could be used. In other words, the processing consists of the non-oily content of the raw oil being separated and removed, rendering the oily content of the oil 100 per cent. Thus, it falls within the scope of the decision that the quality of the oil had been improved and therefore it does not negative its continuing to be oil. In refining the same, purifica....