Flower seeds qualify as planting material under customs exemption entry, making denial of exemption unsustainable.

Flower seeds imported for sowing were found to fall within the express wording of Sl. No. 17 of Notification No. 12/2012-Customs, which covers planting materials including seeds of vegetables, flowers and ornamental plants. The dispute was confined to exemption eligibility, not classification, and a plain reading of the entry supported inclusion of flower seeds. A narrower reading was rejected as artificial and inconsistent with the language of the notification, so denial of the exemption was unsustainable.

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Issues: Whether flower seeds imported for sowing were eligible for exemption under Sl. No. 17 of Notification No. 12/2012-Customs.

Analysis: The exemption entry covered planting materials, including seeds of vegetables, flowers and ornamental plants. The dispute concerned only the availability of exemption to flower seeds, not their classification. On a plain reading of the entry, seeds of flowers fall within the express language of the notification. The contrary view treated the wording in an artificial manner and led to an unreasonable result inconsistent with the text of the entry.

Conclusion: Flower seeds were held eligible for exemption under Sl. No. 17, and denial of the exemption was unsustainable.

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