Fresh psyllium seeds in unprocessed form qualify for exemption under the specific heading-based GST entry.

Psyllium seeds supplied in their natural, raw and unprocessed state, without drying, freezing, crushing or similar processing, were treated as fresh agricultural produce and therefore exempt under Entry 87 of Notification No. 10/2025-Central Tax (Rate). The ruling applied the tariff heading, HSN notes and common parlance to hold that the absence of processing preserved the goods' fresh character. The alternative claim that the same goods were exempt as "goods of seed quality" under Entry 77 was not separately accepted, because the specific fresh-goods exemption under heading 1211 governed the supply.

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Issues: (i) Whether psyllium seeds supplied in their natural, raw and unprocessed form, without drying, freezing, crushing or other processing, qualify as "fresh" psyllium seeds and are exempt under Entry 87 of Notification No. 10/2025-Central Tax (Rate) dated 17.09.2025. (ii) Whether the same goods qualify as "goods of seed quality" and are exempt under Entry 77 of Notification No. 10/2025-Central Tax (Rate) dated 17.09.2025.

Issue (i): Whether psyllium seeds supplied in their natural, raw and unprocessed form, without drying, freezing, crushing or other processing, qualify as "fresh" psyllium seeds and are exempt under Entry 87 of Notification No. 10/2025-Central Tax (Rate) dated 17.09.2025.

Analysis: Psyllium seeds were found classifiable under heading 1211 of the Customs Tariff Act, 1975. The supply described by the applicant consisted of seeds procured from farmers through APMC auctions in the same condition as harvested, with no artificial drying, freezing or other processing. Applying the tariff description, the HSN notes, and the GST clarification on the distinction between fresh and dried goods, the Authority treated the goods as fresh agricultural produce in common parlance. Entry 87 of Notification No. 10/2025-Central Tax (Rate) specifically covers plants and parts of plants, including seeds and fruits, of the relevant kind when fresh or chilled.

Conclusion: Yes. The psyllium seeds, as supplied, are fresh and are exempt under Entry 87 of Notification No. 10/2025-Central Tax (Rate) dated 17.09.2025.

Issue (ii): Whether the same goods qualify as "goods of seed quality" and are exempt under Entry 77 of Notification No. 10/2025-Central Tax (Rate) dated 17.09.2025.

Analysis: Entry 77 is a general exemption for all goods of seed quality under Chapter 12, whereas Entry 87 is a specific exemption covering heading 1211. Since psyllium seeds were held to fall squarely within the specific heading-based entry and to be fresh goods, the Authority treated the general seed-quality entry as not requiring separate acceptance for the ruling sought.

Conclusion: No. The claim under Entry 77 was not accepted in view of the finding under Issue (i).

Final Conclusion: The supply of psyllium seeds in the stated unprocessed condition is exempt as fresh goods under the specific heading-based exemption, and no separate exemption was granted on the alternative seed-quality basis.

Ratio Decidendi: Where goods are specifically covered by a heading-based exemption for fresh plant parts, the specific entry governs and the fresh character of the supply is determined by the absence of drying, freezing, or similar processing.

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