In Brief
A trading company (Noble Resources) challenged a customs duty demand on crude degummed soyabean oil imported under a duty-free credit entitlement scheme. The Revenue claimed the oil was an agricultural product and thus excluded from duty exemption benefits. The High Court upheld the demand, but the Supreme Court reversed the judgment. The Court held that crude degummed soyabean oil, resulting from extracting and processing soyabean, is a distinct manufactured product—not an agricultural product. The Court clarified that a product need not be consumable or refined to constitute a separate commodity. Additionally, the Court struck down a departmental circular that had enlarged the notification's exclusionary clause, ruling that administrative circulars cannot curtail statutory benefits.
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