TaxTMI 
TaxTMI 
2026 (9) TMI 1813
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.... 103(1) of the CGST Act, 2017 and the RGST Act, 2017, this Advance Ruling pronounced under Chapter XVII of the Acts shall be binding only: (a) on the applicant who had sought it in respect of any matter referred to in Section 97(2) of the Acts; and (b) on the concerned officer or the jurisdictional officer in respect of the applicant. 3. In terms of Section 103(2) of the CGST Act, 2017 and the RGST Act, 2017, this Advance Ruling shall be binding unless the law, facts or circumstances supporting the original ruling have changed. 4. Under Section 104(1) of the CGST Act, 2017 and the RGST Act, 2017, where the Authority finds that the Advance Ruling has been obtained by the applicant by fraud or suppression of material facts or misrepresentation of facts, it may, by order, declare such ruling to be void ab initio and thereupon all the provisions of the Acts or the Rules made thereunder shall apply to the applicant as if such Advance Ruling had never been made. 5. Any appeal against this Advance Ruling shall lie before the Appellate Authority for Advance Ruling, Rajasthan, in terms of Section 100 of the CGST Act, 2017 and the RGST Act, 2017. Such appeal shall ....
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....principal place of business or any additional place(s) of business. • The Applicant proposes to undertake the following activities for purchase and sale of fresh Psyllium seeds in the ordinary course of business: i. Psyllium seeds (Isobgul) are procured from farmers through auctions conducted by Agricultural Produce Market Committees (APMCs) / Krishi Upaj Mandi Samiti (KUMS) directly or through subsequent traders in the same form and condition. The farmers undertake only threshing, i.e. separation of seeds from the plant, without causing any change in the form, character or composition of the seeds and in the same form it will be purchased and further sold by the Applicant. ii. After procurement, the seeds are stored in godowns in the same condition, without undertaking any processing activity or drying. iii. The said Psyllium seeds (Isobgul) are thereafter supplied, without processing, to traders or customers. iv. The commodity proposed to be supplied is raw and fresh Psyllium seeds (Isobgul), being an agricultural produce. v. At no stage, whether prior to procurement from farmers or prior to subsequent supply to traders/cu....
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....0 - Other : --- Seeds, Kernel, Aril, Fruit, Pericarp, Fruit rind, Endosperm, Mesocarp, Endocarp : 1211 90 11 ---- Ambreue seeds 1211 90 12 ---- Nuxvomica, dried ripe seeds 1211 90 13 ---- Psyllium seed (Isobgul) • The Applicant submits that classification under Customs Tariff is relevant for determining the classification under GST law as per S. No. (a)(iii) of the Explanation appended in the Notification No. 10/2025 (CGST Rate) dated 17.09.2025. The said explanation is reproduced hereunder: Explanation. - For the purposes of this Schedule, - (a) the expressions, - (iii) "tariff item", "sub-heading" "heading" and "Chapter" shall mean respectively a tariff item, heading, sub-heading and Chapter as specified in the First Schedule to the Customs Tariff Act, 1975 (51 of 1975); Hence, having specific entry for Psyllium seeds under Chapter 12, such seeds squarely fall under this Chapter Heading 1211. • Now coming to the taxability of such Psyllium seeds under GST, the Applicant submits that Entry No. 87 of Notification No. 10/2025-Central Tax (Rate) dated 17.09.2025 is rel....
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....r tamarind kernel? 1. Tamarind kernel of seed quality attracts Nil GST, whereas 2. Tamarind kernel of other than seed quality attracts 5% GST. 15. What is the HS code and the GST rate for Isabgol seeds? 1. Isabgol seeds fall under heading 1211. 2. Fresh Isabgol seeds attract Nil GST. 3. Dried or frozen Isabgol seeds attract 5% GST. Hence, it establishes the intent of the Government also to exempt Fresh Psyllium Seeds from GST. • Psyllium seeds (Isobgul) are traded as it is, after being harvested, in the same form (fresh form) without any further categorization or drying. Hence, seeds supplied in natural, unprocessed form always remain fresh. a) Hence, the Psyllium Seeds falling under HSN 1211 qualifies for exemption as these seeds are fresh produce and proposed to be supplied in the same state as harvested without undergoing any drying or freezing process. In present case, no artificial drying like sun drying or mechanical drying or freezing process is proposed to be carried out. Furthermore, the Applicant submits that these psyllium seeds are used for manufacturing of Psyllium husk which is used for pharmacy purposes for stomach relate....
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....l and nutraceutical ingredient. Further, Psyllium seeds (Isobgul) are agricultural produce derived from the plant Plantago ovata. The said seeds are cultivated by farmers as a seasonal agricultural crop and are harvested in seed form upon maturity. • Upon maturity of the crop, the plants are harvested from the field and the seeds are separated by threshing, which is merely a post-harvest agricultural activity for separating the seeds from the plant material. The material obtained at this stage is raw Psyllium seeds (Isobgul). Such seeds continue to retain their natural botanical identity and physical form, and are therefore supplied as agricultural produce without any change in their essential character. • It is submitted that although "agricultural produce" is not separately defined under the CGST Act, 2017 or under Notification No. 10/2025-Central Tax (Rate) dated 17.09.2025. However, the said expression can be understood from the definition of "Agricultural produce" defined in Notification No. 11/2017-C.T. (Rate) and 12/2017-C.T. (Rate), both dated 28-6-2017 as under: "Agricultural produce" means any produce out of cultivation of plants and rea....
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....M/s Jignesh Kumar Narayandas Patel (Trade Name: Akshar Traders) has pronounced the ruling that the Psyllium seeds (Isobgul) are exempted under Entry No. 87 of (HSN 1211) of Notification No. 10/2025 dated 17.09.2025 as "Plants and Parts of Plants" (including Seeds and Fruits) of a kind used primarily in perfumery, in pharmacy or for insecticidal, fungicidal or similar purpose, fresh or chilled. Copy of AAR is enclosed and marked as Annexure-4. The relevant portion of the 'Ruling' is given hereunder: "25. We find that the aforementioned Notification covers a comprehensive list of products/items which are exempt from GST. On going through the aforementioned Notification, we find that there are two entries i.e. Entry No.77 which reads as "All goods of seed quality" covering Chapter 12 and the other is Entry No.87 covering heading 1211 and reads as "Plants and parts of plants (including seeds and fruits), of a kind used primarily in perfumery, in pharmacy or for insecticidal, fungicidal or similar purpose, fresh or chilled". As discussed earlier, the product 'Psyllium seeds' is part, of plant (seed) and is used in pharmacy for the production of 'Isobgul'. Moreover, the said see....
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.... Powder, has made important observations regarding the botanical nature and predominant use of Psyllium which is directly relevant for interpreting Entry No. 87 of Notification No. 10/2025-Central Tax (Rate). • While analysing the product, the Authority first examined the meaning and commercial understanding of the expression "Psyllium". Referring to standard reference sources, the Authority observed that Psyllium (commonly known as Isobgul) belongs to the genus Plantago and that its seeds are commercially used for the production of mucilage. The Authority further noticed that Psyllium is extensively recognised for its medicinal properties and is widely used as a natural dietary fibre and laxative. After considering the botanical literature and dictionary meanings, the Authority recorded the following finding: "Psyllium (commonly known as Isobgul) is a plant whose parts such as seeds and others are used to prepare pharmacy products, especially laxative medicines." • Hence, your honour, has recognised in your previous ruling that Psyllium is a medicinal plant and that its seeds constitute the source material for pharmaceutical preparations. This fi....
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....hat the Psyllium seeds (Isobgul) is exempt from GST falling under Sr.No.87 and Sr. No. 77 of Notification No. 10/2025-Central Tax (Rate) dated 17.09.2025. S. No. Chapter/ Heading/ Sub-heading/ Tariff item Description of goods 77. 12 All goods of seed quality Additional Submission: - 1. The Applicant submitted in tabular format the flowchart of cultivation of Isobgul seeds to its subsequent proposed sale by the Applicant. Flow of Psyllium Seeds (Isobgul) from Cultivation to Subsequent Trading S.No. Stage Activity undertaken Condition of Psyllium Seeds Processing / Value Addition 1 Cultivation & Harvesting Isobgul crop is cultivated by farmers in agricultural fields. The mature Isobgul crop is harvested by the farmers. Seeds remain naturally contained in the mature crop. Harvested crop contains the plant material along with the seeds. No processing. 2 Threshing Farmers undertake threshing only for separating the Psyllium seeds from the harvested plant. Whole Psyllium seeds are separated from the plant in their original form. Mere separation of seeds; no change in form, character, composition or essential nature. ....
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....soever. ii. No Change in Identity of the Product: The identity, form and essential character of the seed remain unchanged from the stage of procurement to the stage of supply. iii. Storage in Normal Godowns: The Isobgul seeds are stored in a normal godown and do not need any specialized godowns like Cold Storage facilities. Rather, during sale of seeds during auction, it is stacked in open lots and sold which means no processing, no activity carried out and no special care is required to be taken as the product remains same as raw and unprocessed and fresh. iv. The seed remains of seed quality. The seed purchased by the Applicant is whole, unbroken and viable, and retains its capacity to germinate, therefore, it is of seed quality. 3. Entry 87 of Notification No. 10/2025-Central Tax (Rate) dated 17.09.2025, exempts goods of Heading 1211 that are "fresh or chilled". Heading 1211, and Entry 87 in terms, cover "plants and parts of plants (including seeds and fruits)". The expression "fresh" must accordingly be understood in a sense appropriate to the goods it governs, which expressly include seeds. 4. The Applicant submits that "fresh" has not been def....
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....its which, when fresh, are covered under Headings 08.01 to 08.06. If the dried fruits are relatable to the fresh fruits classified under the Headings 08.07 to 08.10, they would fall in the category of 'other fruits' in 0813.40. The dried fruits, for the purpose of this Heading, may be prepared either by drying directly in the Sun or by industrial process like tunnel drying. The last portion of the Explanatory Note to Heading 08.13 states that products consisting of mixtures of one or more of the dried fruits of this Heading with plants or parts of plants of other Chapters or with other substances, such as one or more plant extracts, are excluded. Reference is made to Heading 21.06 in this regard. This Note, however, is not applicable to the goods in question, as they are not mixed with other plants or parts of plants." 7. As per above, it can be understood that "dried" means a planned process of drying and once product does not undergo the drying process, it will remain as fresh product. 8. This interpretation is line with the clarification of the Board itself. Circular No. 163/19/2021-GST dated 06.10.2021, in the cognate context of Chapter 8, explains that produce "continue[....
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....e Market Committee (APMC)/KUMS auctions from farmers/cultivators directly or through subsequent traders, without undergoing any drying, freezing, crushing or other processing qualifies for exemption under Entry 87 (HSN 1211) of Notification No. 10/2025-Central Tax (Rate) dated 17.09.2025 as "Plants and parts of plants (including seeds and fruits) of a kind used primarily in perfumery, in pharmacy or for insecticidal, fungicidal or similar purpose, fresh or "chilled"? Q2) If Answer to Question (1) is No, whether Psyllium Seeds (Isobgul) being goods of seed quality and capable of sowing and germination as discussed above qualifies for exemption from GST under Entry 77 (HSN 12) of Notification No. 10/2025-Central Tax (Rate) dated 17.09.2025?" Q3) If the answers to Questions (1) and (2) are both in the negative, what is the correct classification of, and the rate of tax applicable to, the supply of the said Psyllium Seeds (Isobgul) by the Applicant? D. COMMENTS OF THE JURISDICTIONAL OFFICER:- Comments received from the Office of Assistant Commissioner, Central Tax, CGST Division-JODHPUR RURAL, SECOND FLOOR, BSNL BUILDING, SECTOR-E, NEAR POST OFFICE, SHASTRI NAGAR, Jodhpur, ....
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....quent mechanical operation undertaken after harvesting to separate the seeds from the spikes, straw and other plant material. b) The agricultural literature itself describes threshing under the separate heading "Post Harvest Technology," stating that harvested plants are spread for few days and thereafter threshed by tractor or bullocks. This clearly identifies threshing as a post-harvest activity rather than harvesting itself. c) Threshing is a critical mechanical process that separates the marketable psyllium seeds from the non-marketable straw, spikes and other crop residues. Without threshing, the harvested crop cannot yield the commercial seed intended for sale. d) The fact that threshing does not amount to manufacture does not necessarily mean that it is part of harvesting. An activity may fall short of manufacture yet still constitute a post-harvest processing operation. e) Therefore, the proposition that threshing is merely harvesting activity is not supported by the agricultural process itself. Rather, threshing is a distinct post-harvest mechanical operation performed after the crop has been harvested and, in the case of psyllium, after....
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....commodity answers the description of "frozen" or "dried" goods. Accordingly, the applicability of Entry No.71 depends upon the factual determination of the condition in which the Psyllium Seeds are supplied. 5. Examination of Notification No. 10/2025-Central Tax (Rate) dated 17.09.2025: Entry No. 87 of Notification No. 10/2025-Central Tax (Rate) dated 17.09.2025 exempts: S.No. Chapter/Heading/Sub-heading/Tariff item Description of goods 87 1211 Plants and parts of plants (including seeds and fruits), of a kind used primarily in perfumery, in pharmacy or for insecticidal, fungicidal or similar purpose, fresh or chilled A plain reading of the entry makes it evident that the exemption is not available to all goods falling under Heading 1211. As per the notification the description of which is specified in column (3) of the Schedule appended to this notification, falling under the tariff item, sub-heading, heading or Chapter, as the case may be, as specified in the corresponding entry in column (2) of the said Schedule, from the whole of the central tax leviable thereon under section 9 of the Central Goods and Services Tax Act, 2017 (12 of 2017). Therefore....
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....any other processing, the commodity appears to answer the description of fresh Psyllium Seeds. d) In this regard, the applicant has merely stated that no processing is undertaken after procurement from farmers. However, absence of processing does not ipso facto establish that the goods supplied are "fresh or chilled". It is a matter of common commercial understanding that psyllium seeds, after harvesting, are rendered fit for storage, transportation and marketing only after reduction of moisture content. Such goods are commercially traded in dried form. Therefore, merely because the applicant purchases the goods directly from farmers or does not undertake any further processing cannot alter the nature and condition of the goods. Further, exemption notifications are required to be construed strictly and the burden of proving eligibility rests upon the person claiming the exemption. Unless the applicant clearly establishes that the goods satisfy all the conditions of Entry No. 87, the benefit of exemption cannot be extended. This principle has been authoritatively laid down by the Constitution Bench of the Hon'ble Supreme Court in Commissioner of Customs v. Dilip Ku....
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....bgul. The Psyllium seeds shall be procured from farmers through auctions conducted by Agricultural Produce Market Committees (APMCs)/ Krishi Upaj Mandi Samiti (KUMS) directly or through subsequent traders in the same form and condition. The Applicant proposes to further sell /supply such fresh Psyllium seeds (isobgul) in the market to the intended customers viz. Manufacturing Units/Traders etc. The Applicant stated that the Psyllium seeds shall be purchased and sold without undertaking any processing, drying or value addition to these seeds. 4. The applicant has asked the following question before the Advance Ruling Authority: Q1) Whether fresh Psyllium Seeds (Isobgul) procured through Agricultural Produce Market Committee (APMC)/KUMS auctions from farmers/cultivators directly or through subsequent traders, without undergoing any drying, freezing, crushing or other processing qualifies for exemption under Entry 87 (HSN 1211) of Notification No. 10/2025-Central Tax (Rate) dated 17.09.2025 as "Plants and parts of plants (including seeds and fruits) of a kind used primarily in perfumery, in pharmacy or for insecticidal, fungicidal or similar purpose, fresh or "chilled"? ....
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....asil, borage, ginseng, hyssop, liquorice, all species of mint, rosemary, rue, sage and wormwood. Heading 1211 does not, however, apply to: (a) medicaments of Chapter 30; (b) perfumery, cosmetic or toilet preparations of Chapter 33; or (c) insecticides, fungicides, herbicides, disinfectants or similar products of heading 3808. 5. For the purposes of heading 1212, the term 'seaweeds and other algae' does not include: (a) dead single-cell micro-organisms of heading 2102; (b) cultures of micro-organisms of heading 3002; or (c) fertilizers of heading 3101 or 3105. SUB-HEADING NOTE: For the purposes of sub-heading 1205 10, the expression 'low erucic acid rape or colza seeds' means rape or colza seeds yielding a fixed oil which has an erucic acid content of less than 2% by weight and yielding a solid component which contains less than 30 micromoles of glucosinolates per gram. Heading 1211 as per the First Schedule to the Customs Tariff Act, 1975 (51 of 1975) 1211 PLANTS AND PARTS OF PLANTS (INCLUDING SEEDS AND FRUITS), OF A KIND USED PRIMARILY IN PERFUMERY, IN PHARMACY OR FOR INSECTICIDAL, FUNG....
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....1211.30 - Coca leaf; 1211.40 - Poppy straw; 1211.50 - Ephedra; 1211.90 - Other This heading covers vegetable products of a kind used primarily in perfumery, in pharmacy or medicine, or for insecticidal, fungicidal, parasiticidal or similar purposes. They may be in the form of whole plants, mosses or lichens, or of parts (such as wood, bark, roots, stems, leaves, flowers, petals, fruits and seeds (other than oleaginous fruits and oil seeds classified in headings 12.01 to 12.07), or in the form of waste resulting, in the main, from mechanical treatment. They remain in the heading whether fresh, chilled, frozen or dried, whole, cut, crushed, ground or powdered or (where appropriate) grated or hulled. Products of this heading impregnated with alcohol remain classified here. Plants and parts (including seeds and fruits) of trees, bushes, shrubs or other plants are classified here if of a kind used directly for the purposes specified above or if used for the production of extracts, alkaloids or essential oils suitable for those purposes. On the other hand, the heading excludes seeds and fruits of a kind used for the extraction of fixed oils; t....
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....dated 17.09.2025, Entry No.87 (covering HSN 1211) which reads as 'Plants and parts of plants (Including seeds and fruits), of a kind used primarily in perfumery, in pharmacy or for insecticidal, fungicidal or similar purpose, fresh or chilled, exempts the product from GST. 2. As per Notification No. 10/2025-Central Tax (Rate) dated 17.09.2025, Entry No.77 (covering HSN 12) reads as 'All goods of seed quality' exempts the product from GST. 3. As per Notification No. 09/2025-Central Tax (Rate) dated 17.09.2025, Entry No.71 (covering HSN 1211) reads as 'Plants and parts of plants (Including seeds and fruits), of a kind used primarily in perfumery, in pharmacy or for insecticidal, fungicidal or similar purpose, frozen or dried, whether or not cut, crushed or powdered.' GST rate here is 5%. 8. We find that in order to decide whether rate of tax is "exempted" or "5%", the test of eligibility hinges on whether the goods supplied by applicant (not purchased by applicant) are "fresh or chilled" or "of seed quality" or "frozen or dried". We find that the applicant has detailed the entire process followed for obtaining Psyllium seeds in their additional submission w....
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....supplied, without processing, to traders or customers; that the commodity proposed to be supplied is raw and fresh Psyllium seeds (Isobgul), being an agricultural produce and at no stage, whether prior to procurement from farmers or prior to subsequent supply to traders/customers, are the Psyllium seeds (Isobgul) subjected to any process, treatment or value addition including drying; that no activity such as cleaning, sorting, grading, roasting, drying, freezing or any other process is undertaken which may alter the form, character or essential nature of the seeds. 9.1 We find that applicant has emphasized that subject goods will be traded in the same form as procured by them from farmers. It is important to note that to be eligible for exemption from tax, the goods should be "fresh or chilled" at the time of supply by the applicant. The applicant has shown in the flow chart that the Psyllium seeds are stored in their Godown after obtaining delivery of seeds through auction process. We find that there is no information on record about the period of storage and in fact it cannot be predicted, secondly when the goods will be stored in godowns, undoubtedly the purpose is to d....
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....s. It may be noted that in terms of note 3 to Chapter 8, dried fruits, even if partially re-hydrated, or subject to preservation say by moderate heat treatment, retain the character of dried fruits or dried nuts. 3.3. Therefore, exemption from GST to fresh fruits and nuts covers only such products which are not frozen or dried in any manner as stated above or otherwise processed. Supply of dried fruits and nuts, falling under heading 0801 and 0802 attract GST at the rate of 5%/12% as specified in the respective rate Schedules." 12. We find that the above para refers to fresh nuts falling under headings 0801 and 0802 and explains that fresh fruit and nuts would cover fruit and nuts which are meant to be supplied in the state as plucked and would continue to be fresh even if chilled. It is further mentioned therein that fruit and nuts do not qualify as fresh, once frozen (cooked or otherwise), or intentionally dried to dehydrate including through sun drying, evaporation or freezing, for supply as dried fruits or nuts. It is further mentioned therein that exemption from GST to fresh fruits and nuts covers only such products which are not frozen or dried in any manner....
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....h are not frozen or dried in any manner as stated above or otherwise processed". Emphasis is applied on the phrase "dried in any manner" and we find that the psyllium seeds are stored in a dry ventilated place which renders them a dried character. Hence we do not agree that the subject goods can be considered as 'fresh' at the time of supply by applicant. 15. Now, since the applicant wants to know whether the Psyllium seeds are exempted or taxable, we will be required to refer to Notification No. 09/2025-Central Tax (Rate) dated 17.09.2025 as well as Notification No. 10/2025-Central Tax (Rate) dated 17.09.2025 to ascertain the aspect of GST liability. Notification No. 09/2025-Central Tax (Rate) dated 17.09.2025 reads as under: GOVERNMENT OF INDIA MINISTRY OF FINANCE (DEPARTMENT OF REVENUE) NOTIFICATION NO 9/2025-Central Tax (Rate) New Delhi, the 17th September, 2025 In exercise of the powers conferred by sub-section (1) of section 9 and sub-section (5) of section 15 of the Central Goods and Services Tax Act, 2017 (12 of 2017), and in supersession of the notification of the Government of India in the Ministry of Finance (Department of Revenue), No....
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....al Tax (Rate) dated 17.09.2025. 17. Next, we need to refer to Notification No. 10/2025-Central Tax (Rate) dated 17.09.2025 which reads as under: GOVERNMENT OF INDIA MINISTRY OF FINANCE (DEPARTMENT OF REVENUE) NOTIFICATION No. 10/2025-Central Tax (Rate) New Delhi, the 17th September, 2025 G.S.R ...- (E). - In exercise of the powers conferred by sub-section (1) of section 11 of the Central Goods and Services Tax Act, 2017 (12 of 2017), and in supersession of the notification of the Government of India in the Ministry of Finance (Department of Revenue), No. 02/2017-Central Tax (Rate), dated the 28th June, 2017 published in the Gazette of India, Extraordinary, Part II, Section 3, Sub-section (i), vide number G.S.R. 674(E), dated the 28th June, 2017, except as respects things done or omitted to be done before such supersession, the Central Government, being satisfied that it is necessary in the public interest so to do, on the recommendations of the Council, hereby exempts intra-State supplies of goods, the description of which is specified in column (3) of the Schedule appended to this notification, falling under the tariff item, sub-heading, heading or....
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....have access to the facts of that case. As per section 103 of the CGST Act 2017, the above referred ruling does not have a binding effect. 20. In view of the foregoing facts, circumstances and provisions of the GST law, we pass the following ruling:- RULING Q1) Whether fresh Psyllium Seeds (Isobgul) procured through Agricultural Produce Market Committee (APMC)/KUMS auctions from farmers/cultivators directly or through subsequent traders, without undergoing any drying, freezing, crushing or other processing qualifies for exemption under Entry 87 (HSN 1211) of Notification No. 10/2025-Central Tax (Rate) dated 17.09.2025 as "Plants and parts of plants (including seeds and fruits) of a kind used primarily in perfumery, in pharmacy or for insecticidal, fungicidal or similar purpose, fresh or "chilled"? Ans.- No, Psyllium Seeds (Isabgol) procured through Agricultural Produce Market Committee (APMC)/KUMS and supplied by the applicant can not be said to qualify as "fresh" Isabgol seeds and are not exempted under Entry 87 (HSN 1211) of Notification No. 10/2025-Central Tax (Rate) dated 17.09.2025 as "Plants and parts of plants (including seeds and fruits) of a kind used prim....