Supreme Court Clarifies Key Tax Exemption Case: Customs Duty Exemption Upheld for Soybean Oil Imports
The Supreme Court ruled that crude degummed soybean oil is not an agricultural product but a distinct manufactured commodity, entitling the appellant to duty exemption under Notification No. 53/2003-Cus. The Court held that a circular (No. 10/2004) cannot expand statutory exclusions beyond the notification’s scope. It clarified that manufacturing processes creating new marketable products alter the original commodity’s identity, and exemptions must align with statutory intent, not administrative clarifications. The judgment reinforces the primacy of statutory notifications over executive circulars.
Facts Of The Case:
The appellant, Noble Resources and Trading India Pvt. Ltd. (formerly Andagro Services Pvt. Ltd.), a recognized export house, imported crude degummed soybean oil under the Du...