In re Jai Mata Di (GST AAR Rajasthan)
The Rajasthan Authority for Advance Ruling (AAR) has ruled that Psyllium Seeds (Isabgol) purchased from farmers through Agricultural Produce Market Committee (APMC) auctions and subsequently stored by a trader in dry and ventilated godowns cannot qualify as “fresh” Isabgol seeds for GST exemption. According to the AAR, such seeds acquire the character of “dried” goods by the time they are supplied by the applicant and consequently attract GST at 5% under Notification No. 09/2025-Central Tax (Rate) dated 17.09.2025. The ruling assumes significance because the Gujarat AAR had recently reached the opposite conclusion on substantially similar Psyllium seed supplies.
Issue Before Rajasthan AAR
The applicant, M/s Jai Mata Di, proposed to purchase Psyllium Seeds directly from farmers through APMC auctions in Rajasthan and supply them to Isabgol processing units. According to the applicant, no drying, freezing, crushing, grading, polishing, chemical treatment or other processing would be undertaken. The seeds would merely be stored in dry and ventilated godowns before onward supply. The underlying tariff classification was not seriously disputed: Psyllium seed is specifically covered by tariff item 1211 90 13. :contentReference[oaicite:0]{index=0}
The principal question was whether these seeds qualified as “fresh or chilled” goods exempt under Entry 87 of Notification No. 10/2025-Central Tax (Rate). Alternatively, the applicant sought exemption under Entry 77 covering “all goods of seed quality”. The distinction was commercially important because Entry 71 of Notification No. 09/2025-Central Tax (Rate) covers specified products under HSN 1211 that are frozen or dried and attracts GST at 5%.
Applicant Relied on Natural and Unprocessed Character of Isabgol
The applicant’s case centred on the absence of any deliberate processing. Psyllium was harvested and threshed by farmers, packed and brought to APMC mandis. The trader proposed to purchase the seeds in that condition and supply them without altering their form, character or composition. The applicant argued that ordinary storage and natural loss of moisture could not convert an agricultural commodity into a deliberately “dried” product.
