TaxTMI 
TaxTMI 
2005 (12) TMI 203
X X X X Extracts X X X X
X X X X Extracts X X X X
....lating to the issue involved in this ground are that the assessee is carrying on business of manufacturing/processing certified seeds as well as labelled seeds for Bajra crops had filed its return of income for assessment year 1998-99 declaring an income of Rs. 2,68,24,810 on 2-10-1998. During the course of assessment proceedings, the Assessing Officer noticed that the assessee's turnover of certified seeds was Rs. 2,10,19,072 and of labelled seeds was Rs. 60,01,92,742. 3.2 Since the assessee was manufacturing/processing certified seeds it had to procure a Certificate from Gujarat State Seed Certification Agency, a State owned Agency to supervise and control the production and manufacturing of certified seeds; had to provide foundation seed to farmers in addition to know-how, etc. and for that purpose was to get itself registered as co-producer. In this system of carrying on the business, the assessee was definitely to incur expenditure. It was, in view of these facts that the assessee had claimed the total processing charges at Rs. 50,80,976. 3.3 The Assessing Officer, considered that the sale of certified seeds (at Rs. 2,10,19,072) was only 25.88% of total sales, i.e., 25.8....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... expenditure without pointing out as to whether the assessee had claimed any expenditure with relation to certified seeds or not. The issue is, therefore, remanded back to the file of CIT (Appeals) with the directions that the same may be decided afresh in accordance with law and with a speaking order after allowing the assessee a proper opportunity of being heard and keeping in view the final outcome of Revenue's appeal for the assessment year 1997-98. 6. Coming to issue involved in ground No. 1, the ld. DR has supported the order of the Assessing Officer, after relying on the order of the ITAT Ahmedabad Bench 'A' in assessee's own case (ITA No. 1110/Ahd./2004) for the assessment year 2000-01, dated 29-10-2004 wherein the Tribunal rejected the assessee's claim of deduction under section 80-I by observing as under:- "5. After considering the rival submissions and going through the material on record, we find that the assessee is engaged in processing and distribution of agricultural seeds. The assessee purchases and supplies foundation seeds to growers and the same are cultivated by agriculturists in their fields and they are offered to assessee to purchase. Assessee purchase....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ities out of raw materials with the help of systematic activity to be entitled to claim deductions under sections 80-I and 80-IA of the Act, which has not been done by assessee in this case. In this case seed is raw material and end product is seed. Assessee is not purchasing food grains but only seeds are being purchased from growers so there is no question of any genetic or chemical irreversible change in raw material. So the ratio of the decision of Hon'ble Supreme Court in the case of Krishi Utpadan Mandi Samiti v. Pilibhit Pantnagar Beej Ltd. is of no help to the assessee. Various decisions based on the decision in the case of Krishi Utpadan Mandi Samiti v. Pilibhit Pantnagar Beej Ltd. also do not help the assessee. Even the contents of partnership deed of assessee firm, agreement entered by the assessee with agriculturists docs not help the assessee. The details of salary and process render no help to assessee as far as allowability of deduction under sections 80-I and 80-IA is concerned. It is only paper work. In view of the above discussion, we are of the view that no interference from our side is called for and the appeal is liable to be dismissed. We order accordingly." ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....D 703 (Ahd.) and the order of Tribunal in that case for assessment year 1983-84 allowing the deduction under section 80-I and under section 80HHA of the Act having been confirmed by the Hon'ble Apex Court, there is no necessity to enter into the arguments as to which of the Tribunal's order (in assessee's case) be followed. According to him, it is well-settled law relating to precedent and judicial proprietary that facts and circumstances remaining the same, it is the decision of Jurisdictional High Court or of the Apex Court, which has the binding precedent and is to be followed - irrespective of conflicting decision of the Tribunal or High Courts - if there is decision of Apex Court; and since in the present case, the issue is covered in favour of Assessee and against the Revenue by the decision of Hon'ble Supreme Court of India in the case of Navbharat Seeds (P.) Ltd. The order of the CIT (Appeals) on this point may be confirmed. (ii) Further, the ld. Counsel for the assessee, has supported the order of the CIT (Appeals) by relying on the following decisions:- (a) Decision of ITAT Ahmedabad Bench 'D' in assessee's own case for assessment years 1992-93, 1993-94 and 1995-96 ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....dard. All these purity standards, namely, germination, moisture and inert matters are tested in the Government Notified Laboratory and seed lot is released as certified only if the lots meet the standards. Processed seed then has to be treated with prescribed doses of poisonous chemicals by putting both the chemicals and the seed in seed F treating drums and seed treatment process is carried out which coats each and every seed with poisonous chemicals which protects the hybrid seed from diseases and insects even after sowing. It was pleaded that this process is mandatory for getting the seed certified. Processed and treated seed is then packed in cloth bags having designs as approved by the Seed Certification Agency. All this process has been explained in the arguments by the ld. AR of the assessee in para 6.2 of the impugned order. After considering these submissions, the CIT(A) relying on the following decisions has held that the assessee is entitled to deduction under section 80-I as the process carried out by the assessee meets the requirements of section 80-I. (i) Tarai Development Corpn. v. CIT 120 ITR 342 (All.) (ii) ITO v. Navbharat Seeds (P.) Ltd., ITAT, Ahmedabad. V....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ing therein the factual aspects of the case. A copy of this note was also directed to be supplied to the DR. There has been no request from the side of the Revenue to be heard in respect of the said detailed note furnished on behalf of the assessee. In other words we proceed to record that the facts stated in the note remain unchallenged and are the accepted facts between both the parties. We now proceed to state these undisputed facts: 'Navbharat Seeds Private Limited, a company registered on 23rd April, 1981 under the Companies Act, 1956 having its registered office at 4, Sarvodaya Commercial Centre, Salapose Road, Ahmedabad. The company is engaged in production, processing and marketing of various hybrid seeds of different crops such as hybrid bajra, hybrid cotton, hybrid jowar, hybrid maize and hybrid castor etc. The activities of the company comprises of the following:- (1) Production of hybrid seeds; (2) Processing of hybrid seeds (3) Testing and quality control (4) Marketing of seeds. All the above activities are conducted as per the 'Indian Minimum Seeds Certification Standards' stipulated by Central Seed Certification Board, Department of Agriculture and ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....nts. After harvesting threshing, the samples are drawn by the staff of State Seed Certification Agency and tested at Government Seed Testing Laboratories for germination, physical purity and genetic purity. If this seed conforms to the standards prescribed by the Government of India in the Minimum Seed Certification Standards then it will be certified seed. (2) Manufacturing Process: Seed processing sequence and equipment: (a) Moisture meter: Testing moisture content to decide need for drying. (b) Air screen cleaner: to clean the seed. (c) Gravity separator: To upgrade the quality of seed. (d) Slurry treater: To treat the seed with chemicals for protection-against insects and micro-organisms. On receipt of the raw seed from the fanner's field the seeds are dried and tested for moisture content. Afterwards the seeds are cleaned on Air Screen cleaner. This process remove immature seed, dust particles, plant materials, offsize seed diseased or insect damaged seed etc. After basic cleaning the seeds are upgraded on Gravity separator to improve the quality of seed by using weight component difference between seeds. The seed then treated with 1% mercurial fungicides and....
X X X X Extracts X X X X
X X X X Extracts X X X X
....d female foundation seed, certification work, arrangement for ginning and successful completion of the programme. 4. The sub-producer shall set apart the required area of levelled, fertile land with facilities for healthy seed production. 5. Main producer will provide male and female foundation seed for this programme to the sub-producer, which is to be used only for the above referred seed programme. 6. Sub-producer shall pay for the expenses for land preparation, irrigation, sowings, interculturing, fertilizers, plant protection, pesticides, rogueing, cross pollination and other expenses. 7. Main producer will provide guidance by technical personal to maintain the purity of the seed, and instructions from the seed certification agency shall be observed and implemented by the sub-producer and accordingly, rogueing and removal of selfed bolls would be arranged and paid for by the sub-producer. 8. Sub-producer will co-operate and follow the instructions given for maintaining the purity of the above referred seed production, by the Seed Certification Agency and officials of the main producer. 9. Sub-producer will bring the seed of cotton at his cost for ginning and ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....e and assistance from day-to-day but even thereafter is engaged in the complicated activities of testing, quality control and the final activity of marketing the seeds through its distributors and dealers. The activities of the company are more or less identical to those as considered by the Allahabad High Court in the case of Tarai Development Corpn. The distinguishing feature sought to be brought out by the learned DR does not appear to be correct. The other arguments advanced by the DR are also not of any avail vis-a-vis the case of the revenue since these run contrary to the various other decisions relied upon by the assessee's counsel including those of the Tribunal. 11. In the final analysis we uphold the order of the CIT(A) vis-a-vis the claims of the assessee under sections 80HHA and 80-I. 12. The appeal is dismissed." (iii) With regard to the decisions of Hon'ble Supreme Court relied upon by the ld. DR, the ld. Counsel for the assessee had submitted that the same been distinguishable both in facts and law, were not applicable to the present controversy. (iv) It was, further submitted that so far assessee's case was concerned, the final product, i.e., certified ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....llowed to happen that will not sake the evidence of the public in judicial procedure as such, it would be destructive of the institutional integrity itself. But on the same time, the Hon'ble Tribunal has, further held that a decision on these particular facts and on consideration of the law prevailing at the relevant time can be deviated from it, if some new facts are brought on record or some more cases of higher Courts on the subject has come to its notice. The relevant part of the order as contained in paragraph Nos. 5 to 11 which reads as under:- "5. It is true that a judicial officer including the Tribunal would not be justified or has any right or jurisdiction to come to a conclusion entirely contrary to or different from the one-reached by it on the same facts and if that be allowed to happen that will not sake the confidence of the public in judicial procedure as such, it would be destructive of the institutional integrity itself. The Sayaji Iron & Engg. Co.'s case decision of the Gujarat High Court is however of no much help in these cases. Firstly, because the observations were vis-a-vis assessee's own case in earlier year whereas the present assessees are different on....
X X X X Extracts X X X X
X X X X Extracts X X X X
....sment for the subsequent years. The Tribunal is not shown to have omitted to consider the material facts. The decision of the Tribunal was on a question of fact and no question of law arose which could be directed to be referred under section 66(2) of the Income-tax Act.' 8. Again see in the case of CIT v. Brij Lal Lohia & Mahabir Prasad Khemka [1972] 84 ITR 273 the Supreme Court at page 277 observed as under: 'The fact that in the earlier proceedings, the Tribunal took a different view of those deeds is not a conclusive circumstance. The decision of the Tribunal reached during those proceedings does not operate as res judicata. As seen earlier there was a great deal more evidence before the Tribunal during the present proceedings, relating to those gift deeds.' 9. The Supreme Court decision in the case of Indian Oil Corporation Ltd. relied upon by the ld. counsel of the assessee is also in our opinion, of no help to the assessees. In this case, the Supreme Court observed 'That the Division Bench of the High Court in Municipal Corporation was clearly in error in taking the view that the decision of this court (Supreme Court) in Ratnaprabha was not binding on it. In doing s....
X X X X Extracts X X X X
X X X X Extracts X X X X
....are brought on record or some more cases of higher courts on the subject have come to its notice. It would be justified and indeed under a duty to take a view commensurate to the new development and also because each year and each assessee is a separate year and a separate assessee and the principle of res judicata and estoppels did not apply to income-tax proceedings even though the department is one and also because in the earlier order some of the decisions of Supreme Court and the High Court were not considered." 10. After having considered the aforesaid decision and also other decisions on this point, we are of the opinion that so far as both the legal propositions are concerned, there is no dispute, but coming to the binding nature of decision of co-ordinate Bench or of the same Bench, we are of the opinion that this theory is applicable only if, not only the facts and circumstances of the case must remain the same, but the pleadings must also be the same and it is so because it happens many a times that in some cases or at earlier occasion one may not have been able to plead properly or may have failed to bring to the notice of the appellate authority or Tribunal or Court....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... which is to be followed. 13. Coming to the issue on merits, we, after having considered the facts of assessee's case as well as the facts in cases of Navbharat Seeds (P.) Ltd. and Pilibhit Pantnagar Beej Ltd., are of the opinion that the facts of assessee's case are similar to the facts in those cases as the appended Annexures 'A' & 'B' of this order, will reveal. 14. Before coming to the final conclusion we would like to consider both the decisions of the Hon'ble Supreme Court relied upon by the assessee - copies of which have been placed in assessee's paper-book and, therefore, we proceed to consider the same. (i) Decision in case of Pilibhit Pantnagar Beej Ltd.: (a) Facts of this as have been revealed from the order of the Hon'ble Supreme Court were that UP Krishi Utpadan Mandi Adhiniyam, 1964 (hereafter referred to as 'Adhiniyam') was enacted to regulate sale and purchase of agricultural produce. (b) Section 6 provided for declaration of Market area and sections 9 and 10 prohibited business of specified agricultural in such market area without licence. Section 2(a) of this Act, specified (agricultural produce) and Schedule appended to Adhiniyam provided all item....
X X X X Extracts X X X X
X X X X Extracts X X X X
....certify seeds and monitor their production and sales. 2.2 'The Indian Minimum Seed Standards' lays down the minimum seed standards required for each crop which can be certified. 3. Method of Seed Production: 3.1 The company purchases breeder seed from the Agricultural Universities and then produces the next stage, i.e., foundation seeds. These foundation seeds are given to contract farmers for further production to certified seed. This certified seed is sold to trade and subsequently to farmers. Foundation Seed is the progeny of Breeder Seed and certified seed the progeny of Foundation Seed. 4. Procedure of production: 4.1 Purchase of breeder seeds from universities. (Rule 14(a)). 4.2 Classification of foundation seed from breeder seed. (Rule 14(a)). 4.3 Giving foundation seed to contract farmers. (Rule 14 c)). 4.4 Registration of the contract farmers with the State Seed Certification Agency and payment of registration and inspection charges to the agency. (Rule 6(d) & Form I). 4.5 Sowing the foundation seed by the contract farmer in his field. 4.6 Inspection of the farmer's field by an inspector of all the State Seed Certification Agency, at least two....
X X X X Extracts X X X X
X X X X Extracts X X X X
....as completely failed to appreciate the declaration of law in the case of State of Rajasthan v. Rajasthan Agricultural Inputs Dealers Association affirmed by this Court on 21-8-1996. In these orders, two reasonings were adopted lo hold that the transaction of seeds do not attract market fee namely (a) that the definition of agricultural produce includes items specified in Schedule and that wherever it was intended to separately cerealised seeds, they have been distinctly found mentioned in the Schedule and that wherever the Schedule does not include seeds specifically in the serialised item such seeds are not specified agricultural produce and (b) on the process of coating and applying insecticides, other chemicals and poisonous substances the basic character, i.e., its consumption as food by human being or animals is irretrievably lost and that such commodity is distinct from foodgrains. The decision of the State Government does not take into account the first reasoning and treats only that commodity as seeds which is treated with chemicals and that the action, in our view, is apparently and palpably wrong. It is to be noticed that the farmers are paid prices on the certified se....
X X X X Extracts X X X X
X X X X Extracts X X X X
....s. However, in the present case, the trader has not purchased unprocessed seed before chemical treatment, therefore, trader is not liable to pay fee on such purchases. Thus direction issued by Secretary, Agriculture in meeting, dated 16-5-1998 also support trader's stand.' I.A. No. 3 of 2001 is filed by the first respondent for seeking permission to place on record a letter dated 19-1-2000 annexed as Annexure A which is very important for the final adjudication of the case. The said I.A. be taken on record. By the said I.A., the first respondent sought to place on record a letter dated 19-1-2000 addressed by the Principal Secretary, Government of Uttar Pradesh to the Commissioner, Trade Tax Department, Government of Uttar Pradesh directing that instructions be issued to the taxation officers that when the growers or the distributors, seed certification machinery sell the seeds in sealed containers after producing themselves after certification along with the tag of the Uttar Pradesh Certification Agency affixed as under the Central Seed Act, 1966 then in such circumstances, no liability of purchase tax is attracted under section 3 AAAA(4). We have perused the communication dated....
X X X X Extracts X X X X
X X X X Extracts X X X X
....foodgrains as commonly understood. That distinction was borne in mind by the High Court in allowing the writ petition of the respondents, and in our view rightly.' The other decisions cited by the counsel for the appellants will not be of any assistance in deciding the factual disputes involved in the instant case. In our view, the High Court has correctly applied the above judgment. This Court held that no market fee could be levied by the State of Rajasthan on seeds on the ground that a seed was distinct from foodgrains inasmuch as they were not fit for human consumption. The ratio decidendi of the above decision is squarely applicable to this case wherein the appellant seeks to give a wide connotation to the words in the Schedule. In our opinion, that giving a wide interpretation is not possible and as Wheat Seed is not included in the Schedule, the Mandi Samiti is not allowed to levy a market fee on purchase. As the Mandi Samiti plays no role in the trade of the respondent's seeds, it may not be allowed to levy the market fee. It is also not in dispute that the Breeder Seeds are allocated by the Ministry of Agriculture or by the Universities to the various seed producing age....
X X X X Extracts X X X X
X X X X Extracts X X X X
....he Mandi Samiti. Thus the production of seeds is an integrated process and needs to be regulated at every stage, right from the inception, in order to maintain genetic identity and genetic purity. There is no nexus whether the seed has been chemically treated or not and the levy of market fees. Since the seed is a separate commodity from grain, the same is not covered under Schedule 1 of the Adhiniyam and as such no market fee is leviable over the sale and/or purchase of the same. We are, therefore, of the view that the seeds are not specified agricultural produce under the provisions of the Act and, therefore, the business of purchase and sale of seeds under the supervision of Seed Certification Agency established under the Act is not a business of sale and purchase of specified agricultural produce and as such the first respondent is not required to pay the market fee or to take out a licence. We are also of the view that the respondents have grossly erred in ignoring the law settled by this Court in the case of State of Rajasthan v. Rajasthan Agricultural Inputs Dealers Association under Article 141 of the Constitution in demanding market fee on seeds. Since the processing....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... contested. Having seen that note, we are satisfied that the Tribunal was right in coming to the conclusion that the seeds were processed by the assessee and that, therefore, the assessee was entitled to the deduction under section 80HH of the Income-tax Act. The appeals are, therefore, dismissed. Nor order as to costs." (ii) Since the order of the Hon'ble Apex Court in the case of Navbharat Seeds (P.) Ltd is a brief order and has referred to a note considered by the Tribunal. We are of the opinion, it is necessary to consider the order of the Tribunal, relevant part of which has been reproduced in paragraph No. 7(ii)(c) of this order, also. (iii) After careful consideration of the order of the Tribunal we are of the opinion that, any cereal, if after treatment with poisonous chemicals gets rendered unfit for human consumption is altogether a different article or a thing, then the original cereal and production of seed being in the same way, the seed so produced also become unfit for human consumption and ceases to be cereal, meaning thereby that the seed (final product), though original cereal remains one of the ingredients, is an article or thing different from the basic....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... Supreme Court is not applicable to the assessee's case. (ii) Decision of Hon'ble Supreme Court in the case of CIT v. Gem India Mfg. Co. [2001] 249 ITR 307. In this case, the Hon'ble Supreme Court has held that in the absence of any material to show that polished diamond is a new article or thing which is the result of manufacture or production, subjecting raw uncut diamonds to a process of cutting and polishing, which yields the polished diamond, cannot be said to amount to manufacture or production of an article or thing, for the purpose of obtaining the benefit of deduction under section 80-I of the Income-tax Act, 1961. In our opinion, the facts of the case before the Hon'ble Supreme Court were quite different. There was no difference in rough diamonds and final polished diamonds, whereas in case before us the final product, i.e., the seed; which, admittedly, is always unfit for human consumption and ceased to be 'cereals' which is fit for human consumption and cereals is, always, definitely a new article or thing and, therefore, the decision relied upon by the ld. DR is no help to the Revenue. (iii) Decision of Hon'ble Supreme Court in the case of Sacs Eagles Chico....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ffice at 4, Relief Road Sarvodaya (now at 1-Patel Commercial Society, Gulbai Center, Tekra, Ellis Salapose Road, bridge, Ahmedabad. Ahmedabad-6). The company We deal in is engaged Hybrid Bajra, in production, Hybrid Cotton, processing and wheat and marketing of Mustard seed. various hybrid The business seeds of activities are different crops same as those such as hybrid of Navbharat Bajra hybrid Seeds Pvt. Ltd. cotton, hybrid as it is Jowar, hybrid necess....
X X X X Extracts X X X X
X X X X Extracts X X X X
....; for all seed producing compa­nies. 2. All the above Rules and Laws The procedure activities are prescribed by is narrated in conducted as Govt. remain the enclosed per the same for all certificate. "Indian seed producers. Minimum Seeds Certification Standards" stipulated by Central Seed Certification Board, Department of Agriculture &nb....
X X X X Extracts X X X X
X X X X Extracts X X X X
..... The So we enter into contract is an agreement entered into with agroup of with each and grower instead every sub- of individual producer in the grower. Copy of beginning of one such agreement season. is submitted to Accounting the then Assessing period for this Officers in respect is 1-10-1981 of assessment to 30-9-1982. proceeding of However, Assessment years: agreement with 1991-1992, however sub-producer enclosed herewith has got to be again. entered into before commence- ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....; Certification certificate be registered Agency with of GSCCA. with Government empty containers Seed Certifi- and tags to cation Agency establish, the in the name of authentic source Company as main of foundation producer and seed supplied farmer as sub- to growers. producer. 3.4 (c) Technical We have a very This is narrated in guidance: After large team of on the first page distribution of experienced of enclosed foundation seeds, field staff, certificate from company's headed by a GSCCA. technical staff Ph.D. Scientist give guidance to carry, &nb....
X X X X Extracts X X X X
X X X X Extracts X X X X
....le as hybrid seeds plants are harvested that is produced separately, which by crossing of will be thrashed male and female and sealed by seed plants. the supervisors After harvesting, for further threshing, the processing for samples are drawn making it fit for by the staff of use as "Seed". State Seed The "rain from male Certification plant is not "Seed" Agency and tested hence it will not at Government be sent for Seed Testing processing. Laboratories for germination, physical purity and genetic purity. If this seed conforms to the standards prescribed by the Government of India in the Minimum Seed Certification Standards then it will be certified seed. 4.(2)Manufacturing Process: Seed processing sequence and equipment: 4.1(a) Moisture&n....
X X X X Extracts X X X X
X X X X Extracts X X X X
....bsp; of seed produced in this area. However we do test moisture in some of the seed lots. 4.2 (b) Air We use This is a mandatory screen cleaner: mechanised requirement, To clean the grader Machines described seed. for cl....
X X X X Extracts X X X X
X X X X Extracts X X X X
....p; to be done manually. 5. On receipt of As mentioned This is described the raw seed from above Gujarat as mandatory the farmer's field and Andhra requirement in the seeds are Pradesh fall para 3 of the dried and tested in Semi-Arid enclosed for moisture Zone of climate, certificate of content. the moisture GSSCA. Afterwards the content in seed seeds are cleaned produced in this on Air Screen area is naturally cleaner. This controlled. Due process re....
X X X X Extracts X X X X
X X X X Extracts X X X X
....sp; the attack of pest and disease in the field of farmers, who sow the seed for commercial cultivation. 6. In case of This treatment hybrid cotton is applicable seed raw hybrid in case of seed is treated cotton seed in a tank with only. concentrated H. This process will dissolve fuzz, lint and wax of seed coat. After that with lime solution the seed is neutralized. These pr....
X X X X Extracts X X X X
X X X X Extracts X X X X
....perform these as "certified tests on our own. seed" by State Seed Certifi- cation Agency. 8.(4) Marketing: 8.1 The Seed on The same type This is described getting satis- of tags are in point No. 3 of factory test issued by the the enclosed results are supervising certificate. marked with blue officer of tag (Enclosure State Certifi- II) issued by cation Agency Gujarat State who supervises Seed Certifi- the processing cation Agency. activities at our processing As per Seed Act, plant. Such 1966 the seed tags are container and&nb....
X X X X Extracts X X X X
X X X X Extracts X X X X
....bsp; of the enclosed warning is also certificate. compulsory to be printed in RED ink on each container 9. The hybrid Bajra being our seeds are marked main crop, we by the company possess strong mainly in the distributors/ State of Gujarat dealer network and Maharashtra in Haryana, through its Rajasthan, distributors/ ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....eed' produce 'Certified Seed' & 'Labelled Seed'. 4. Company distributes Firm distributes breeder breeder seeds to the seeds to the listed and listed and scheduled scheduled farmers. The farmers. The breeder breeder seed are sown seed are sown and are and are raised under germinated under strict strict supervision of supervision of statutory statutory Seed Seed Certification Agency, Certification Agency, set up under the Seed set up under the Seed  ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....sp; again the lots rejected back from the farmers. After are not taken back from harvesting the approved the farmers. After standardised certified harvesting the approved seeds, are brought to standardised certified processing plant of the firm. seeds, these lots are Only those lots, which fumigated for preser- are not sold immediately vation under the samples and are to be stocked of each lot is tested for longer period, are in the laboratories of fumigated with Cell Seeds Certification phose/Qu....
X X X X Extracts X X X X
X X X X Extracts X X X X
....gly the firm also production, operation is is printing the warning supervised by Seed in red ink "Seed treated Certification Agency. with Poison (Thiram), do not use for Food, feed or Oil purpose" on all the seed packets of 'processed seed'. 8. It was submitted that There is clear-cut clause until the seeds are &nb....