Seed exemption depends on truthful labelling and proof of compliance; authorities may test the declaration when doubt arises.

Rule 7 of the Seeds Rules, 1968 places responsibility on the person named on the mark or label for the accuracy of the required label particulars while the seed remains in the unopened original container. The regulatory authorities are therefore not barred from examining whether the declaration is true where material exists to doubt it. On the facts, the assessee did not produce satisfactory evidence before the assessing, revisional, or appellate authorities to show that the goods met the conditions for the claimed exemption. The exemption claim was consequently rejected and the revision failed.

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Issues: Whether the assessee was entitled to exemption for seeds claimed to be certified and truthfully labelled seeds, and whether the authorities could question the accuracy and genuineness of the labelling.

Analysis: Rule 7 of the Seeds Rules, 1968 makes the person whose name appears on the mark or label responsible for the accuracy of the information required to appear on the label while the seed remains in the unopened original container. The statutory scheme therefore does not bar the regulatory authorities from examining the veracity of the declaration where there is material to doubt it. The assessee also failed to produce any satisfactory evidence before the assessing, revisional, or appellate authorities to establish that the goods satisfied the conditions necessary for the claimed exemption.

Conclusion: The claim for exemption was rightly rejected and the revision failed.

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