2026-VIL-115-AAR
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SGST Advance Ruling Authority

GST – Gujarat AAR - Classification and exemption to Fresh Psyllium Seeds, Agricultural Produce - Whether psyllium seeds supplied in their natural, raw and unprocessed form as procured through APMC auctions directly from farmers, without undergoing any drying, freezing, crushing or other processing, qualify as fresh isabgol seeds and are exempted under Entry 87 (HSN 1211) of Notification No. 10/2025-Central Tax (Rate) dated 17.09.2025 – HELD - The fresh agricultural produce refers to raw, unprocessed food items derived from farming that have not been dried, frozen, or heavily processed and remain in the same state as harvested. Applying the principles enunciated in Circular No. 169/19/2021-GST dated 06.10.2021, the psyllium seeds obtained through APMC auction mechanism on which no artificial or intentional drying, dehydration, freezing, or processing of any kind is undertaken, and which are supplied to processing units in their natural form without any change or alteration from the stage of procurement, satisfy the definition of fresh produce - The product is classifiable under Sub-heading 1211 9013 of the Customs Tariff Act as psyllium seeds are explicitly mentioned in the HSN notes to heading 1211. Since the seeds are plants or parts of plants (seeds) used primarily in pharmacy for the production of isabgol and are supplied in fresh condition, they fall squarely within the ambit of Entry 87 of Notification No. 10/2025-Central Tax (Rate), which provides exemption for plants and parts of plants used primarily in pharmacy when supplied in fresh or chilled condition - The Psyllium seeds supplied in natural, raw and unprocessed form as procured through APMC auctions directly from farmers, without undergoing any drying, freezing, crushing or other processing, are exempted from GST under Entry 87 (HSN 1211) of Notification No. 10/2025-Central Tax (Rate) dated 17.09.2025 and are liable to Nil GST – Ordered accordingly
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