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2025 Supreme(Online)(MP) 9312

MADHYA PRADESH HIGH COURT
, J
Ruchi Soya Industries Ltd. v. State of M. P.


Advocates:
For the Appellants/Petitioners: P.M. Choudhari
For the Respondents: Sudeep Bhargava

1. The present batch of writ petitions has been filed challenging the respective impugned orders passed by the Revisional authority, viz, the Additional Commissioner of Commercial Tax, MP, Indore, confirming the imposition of Entry Tax on the crude Soyabean Oil brought by the petitioners within the State of MP for manufacturing / refining Soyabean Refined Oil.

For the sake of convenience, the facts are being taken from Writ Petition No.57/2009, are as under: -

The petitioner in Writ Petition No.57/2009 Patanjali Foods Limited (Formerly known as Ruchi Soya Industries Limited) has been engaged in manufacturing and selling Soya Oil and De - oiled Cake (DOC). The present matter relates to the period from 01-04-2004 to 31-03-2005. During the said period the petitioner brought a large quantity of crude soya oil by way of import from outside the country and after refining the same, some quantity of refined soya oil was sold outside the state of MP or was sold in the course of interstate trade or commerce without being used or consumed in the state. The assessment for the said period was completed by the learned Assessing Authority viz, the Assistant Commissioner of Commercial Tax Division -


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