Lohlya Edible Oils Private Limited Vs State of Andhra Pradesh (Andhra Pradesh High Court)
The Andhra Pradesh High Court disposed of a batch of writ petitions challenging assessment orders passed against a company engaged in importing crude edible oil and refining it for sale. The petitions related to the assessment years 2021-2022, 2022-2023, and 2023-2024.
The Assessing Authority initiated proceedings on the basis that the standard yield of refined oil from crude oil should be 94.5%. However, the petitioner’s recorded yields were higher, namely 96.79% for 2021-2022, 94.86% for 2022-2023, and 95.43% for 2023-2024. The Assessing Officer held that any yield beyond 94.5% could not be accepted and treated the excess yield as taxable.
The petitioner challenged the assessment orders mainly on the ground of violation of the principles of natural justice. According to the petitioner, after receiving the initial notice, it repeatedly requested the Assessing Officer to disclose the basis and source for fixing the benchmark yield at 94.5%. The petitioner relied on letters dated 28.05.2025, 19.06.2025, and 23.08.2025, along with written objections submitted during the personal hearing on 13.10.2025, to show that such requests were consistently raised.
The Court observed that some assessment orders did not refer to the letters dated 28.05.2025 and 23.08.2025. However, the subsequent representation dated 19.06.2025 specifically referred to the earlier request. The Court also noted that additional submissions during the personal hearing mentioned the same issue.
