In re Jigneshkumar Narayandas Patel (GST AAR Gujarat)
The Gujarat Authority for Advance Ruling (AAR) examined the GST classification and taxability of Psyllium Seeds (Isabgol) proposed to be traded by a registered proprietor engaged in purchasing the seeds from farmers through Agricultural Produce Market Committee (APMC) auctions and supplying them, without any processing, to Isabgol processing units. The applicant stated that the seeds would be procured in their natural form after threshing, stored in warehouses without any processing or value addition, and supplied in the same condition. No drying, freezing, grading, polishing, roasting, crushing, chemical treatment, or any other process altering the nature of the seeds would be undertaken.
The applicant sought a ruling on whether such Psyllium Seeds qualify as “fresh” Isabgol seeds exempt under Entry 87 of Notification No. 10/2025-Central Tax (Rate), which covers plants and parts of plants, including seeds and fruits, used primarily in perfumery, pharmacy, or similar purposes when supplied in fresh or chilled form. Alternatively, the applicant sought exemption under Entry 77 of the same notification as “goods of seed quality.”
The Authority first examined the classification of Psyllium Seeds under the Customs Tariff Act, 1975. Referring to Chapter 12, tariff heading 1211, and the Harmonised System of Nomenclature (HSN) Notes, it noted that Psyllium Seed (Isobgul) is specifically classified under tariff item 1211 90 13. The HSN Notes also specifically include “Plantago psyllium: herbs and seeds.” Accordingly, the Authority concluded that Psyllium Seeds are correctly classifiable under heading 1211.
