Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
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Raw, unprocessed Psyllium seeds (Isabgol) procured directly from farmers through APMC auctions, and supplied without drying, freezing, crushing or other processing, were treated as fresh goods under heading 1211. The Authority relied on tariff and HSN notes to hold that goods retained their natural character up to supply and did not fall within entries for frozen or dried goods. It also held that the specific exemption for fresh or chilled goods under Entry 87 of Notification No. 10/2025-Central Tax (Rate) prevailed over the more general exemption for goods of seed quality. Accordingly, the supply was held exempt from GST.
Raw, unprocessed Psyllium seeds (Isabgol) procured directly from farmers through APMC auctions, and supplied without drying, freezing, crushing or other processing, were treated as fresh goods under heading 1211. The Authority relied on tariff and HSN notes to hold that goods retained their natural character up to supply and did not fall within entries for frozen or dried goods. It also held that the specific exemption for fresh or chilled goods under Entry 87 of Notification No. 10/2025-Central Tax (Rate) prevailed over the more general exemption for goods of seed quality. Accordingly, the supply was held exempt from GST.
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