The Gujarat Authority for Advance Ruling (AAR) has held that psyllium seeds (Isabgol) procured through Agricultural Produce Market Committee (APMC) auctions and supplied in their natural, raw, and unprocessed form are exempt from GST.
The ruling is applicable where no drying, freezing, crushing or other processing is performed.
A coram of CGST Member Vishal Manibhai Nanji and SGST Member Rashmi Vajs ruled in favour of Jigneshkumar Narayandas Patel, proprietor of Akshar Traders.
“The psyllium seeds to be obtained by the applicant through APMC auction mechanism (on which no artificial or intentional drying, no dehydration, no freezing and no processing of any kind is undertaken at any stage by the applicant), which is later on supplied to the processing units, can be considered as ‘fresh’,” the Authority stated.
The trader asked to obtain psyllium seeds from farmers through APMC auctions in Gujarat. Afterwards, the seeds shall be supplied to units involved in extracting Isabgol husk.
As per the application, the seeds shall be stored in ventilated godowns. They shall be supplied in the identical condition in which they were obtained. No drying, dehydration, freezing, grading, roasting, milling, crushing or chemical treatment would be performed.
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The applicant asked for a ruling on whether psyllium seeds supplied in this way qualified as fresh plants and parts of plants, including seeds and fruits, under Heading 1211 and were exempt from GST. Alternatively, it claimed that the goods must be considered as goods of seed quality and allowed for waiver on those grounds.
The authority analysed the tariff classification and the applicable GST notifications, and then it observed that psyllium seeds fall under the tariff heading, which consists of plants and parts of plants, including seeds and fruit
It acknowledged a 2021 circular that specifies the difference between fresh products and products that have been dried or frozen.
The authority observed that the seeds shall be obtained via the APMC auction procedure in the same condition in which they were brought by farmers. After that, they shall be stored in dry and ventilated godowns.
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Before their supply to processing units, no artificial or intentional drying, dehydration, freezing, or processing shall be performed.
The Bench, referring to such reasons, stated that the seeds shall remain in the same natural form from procurement until supply. They shall keep their original characteristics.
“We find that the psyllium seeds to be obtained by the applicant through the APMC auction mechanism (on which no artificial or intentional drying, no dehydration, no freezing and no processing of any kind is undertaken at any stage by the applicant), which is later on supplied to the processing units, can be considered as ‘fresh’,” the Authority affirmed.
Thus, the Authority held that the exemption applies to the psyllium seeds supplied in their natural, raw and unprocessed form under the entry that covers plants and parts of plants falling under Heading 1211.
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Although the bench did not consider the alternative claim that the goods must be deemed as goods of seed quality for exemption.
“Entry No.77 is a general entry covering all goods of seed quality of Chapter 12 whereas Entry No.87 is a specific entry covering products of heading 1211 only and any specific entry would prevail over a general entry and include the Psyllium seeds and apply covered under Entry No.87 of Notification No.10/2025-Central Tax (Rate) dated 17.09.2025 and are liable to NIL GST,” the Authority added.
It concluded that psyllium seeds supplied in the way proposed by the trader shall be covered by the specific exemption applicable to products falling under Heading 1211. Therefore, a nil GST rate is applicable on the supplies.
| Case Title | M/S. Jigneshkumar Narayandas Patel (Trade name: Akshar Traders) |
| Case No. | GUJ/GAAR/R/2026/21 |
| GSTIN | 24BEGPP6511L2ZB |
| For the Applicant | S/Shri Rashmin Vaja, Jitendra Chopra, and Ms. Nency Shah |
| Gujarat AAR | Read Order |
