2026-VIL-146-AAR

SGST Advance Ruling Authority

GST – Rajasthan AAR – Classification and applicable tax rate on Psyllium Seeds (Isabgol) - Whether Psyllium Seeds (Isabgol) supplied in their natural, raw and unprocessed form as procured through Agricultural Produce Market Committee (APMC) auctions directly from farmers, without undergoing any drying, freezing, crushing or other processing qualifies as “fresh” Isabgol seeds and are exempted under Entry 87 (HSN 1211) of Notification No. 10/2025-Central Tax (Rate) dated 17.09.2025 or alternately, qualifies as “goods of seed quality” and are exempt from GST under Entry 77 (HSN 12) of Notification No. 10/2025-Central Tax (Rate) dated 17.09.2025 – HELD - the product ‘Psyllium seeds’ is part of plant (seed) and is used in pharmacy for the production of ‘Isabgol’. Moreover, the said seeds cannot be termed as ‘fresh’ at the time of supply by applicant. Entry No. 87 is a specific entry covering products of heading 1211 only and aptly covers ‘Psyllium seeds’ which are “fresh or chilled” only. Hence, the “Psyllium seeds” being dried, are not covered under Entry No.87 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” - The Psyllium seeds are parts of plants (seeds) of a kind used in pharmacy i.e. manufacture of isabgol, the same is dried, hence the same is covered under the ambit of Entry No.71 of the Schedule-I of Notification No. 09/2025-Central Tax (Rate) dated 17.09.2025 and liable to tax @ 5% GST – Ordered accordingly

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