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Issues:
1. Whether Rice Bran Oil is considered as 'Vegetable oil' under the Vegetable Oil Cess Act, 1983. Analysis: The Supreme Court considered the appeal against the Andhra Pradesh High Court's judgment to determine whether Rice Bran Oil qualifies as 'Vegetable oil' under the Vegetable Oil Cess Act, 1983. The key contention revolved around the definition of 'Vegetable Oil' as it was not explicitly defined in the Cess Act, leading to a reference to Section 3(h) of the National Oil Seeds and Vegetable Oil Development Board Act for clarification. The Development Board Act defines 'Vegetable Oil' as any oil produced from oilseeds or oil-bearing plant materials containing glycerides, excluding oils subjected to post-recovery processing. The Andhra Pradesh High Court had previously ruled in favor of considering Rice Bran Oil as vegetable oil, emphasizing its origin from an oil-bearing plant material. However, the appellant's counsel highlighted conflicting judgments from the Allahabad High Court and the Bombay High Court, which challenged this classification. The Allahabad High Court argued that Rice Bran, being a by-product of rice processing, does not qualify as an oil seed or a typical vegetable oil-bearing material. Additionally, the Bombay High Court's decision considered the legislative intent behind the Cess Act and the Development Board Act, concluding that Rice Bran Oil was not intended to fall under the definition of 'Vegetable Oil' as per Section 3(h) of the Development Board Act. Moreover, the Supreme Court deliberated on the legislative objective of the Cess Act, aimed at funding the National Oil Seeds and Vegetable Oil Development Board to foster the oil seeds and vegetable oils industry. Considering Rice Bran as a by-product of rice processing, extracted through a method unsuitable for human consumption, the Court aligned with the Allahabad and Bombay High Court decisions, excluding Rice Bran Oil from the purview of 'Vegetable Oil' as defined in the Development Board Act. Consequently, the Supreme Court allowed the appeal, overturning the High Court's judgment. The bank guarantees provided by the appellants were discharged, and the appellants were granted the opportunity to seek a refund following the principles established in Mafatlal Industries v. Union of India. No costs were awarded in the matter.
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