Psyllium seed classification treats dried Isabgol as taxable rather than exempt fresh or chilled plant material

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....Psyllium seeds (Isabgol) supplied in natural, raw and unprocessed form after procurement through APMC auctions are classified under Customs Tariff sub-heading 1211 90 13. The seeds are treated as dried rather than "fresh" or "chilled" plants or plant parts and therefore do not qualify for exemption under the relevant entry for fresh or chilled goods under HSN 1211. The stated conclusion treats the supply as taxable at 5%, notwithstanding a conflicting reference to exemption for goods of seed quality.....