Whether loading & unloading service of yellow peas at the port is exempt supply?

In re T P Roy Chowdhury & Company Pvt. Ltd. (GST AAAR West Bangal) There is no dispute that raw whole yellow peas are agricultural produce covered under serial no. 45 of the Rate Notification and are exempted goods. However, this particular consignment of raw whole yellow peas was harvested in foreign land and the concerned primary market or the farmers’ market is located in that foreign land. We observe from a combined reading of entry number 54 of the Exemption Notification and definition 2(d) of the Exemption Notification that all services and processes are excluded beyond the pri...