The Rajasthan Authority for Advance Ruling has held that Psyllium Seeds (Isobgul) procured through APMC auctions and stored in godowns before onward supply cannot be treated as ‘fresh’ and are not exempt under Entry 87 of Notification No. 10/2025-CT (Rate), but are taxable at 5% GST under Entry 71 of Notification No. 09/2025-CT (Rate) as ‘dried’ plants and parts of plants. The ruling by Members Mahipal Singh and Dr. Akhedan Charan in RAJ/AAR/2026-27/17 (M/s Rukhm Industries Ltd., decided 25.08.2026) expressly declines to follow the Gujarat AAR’s ruling in M/s Jigneshkumar Narayandas Patel (Akshar Traders) (GUJ/GAAR/R/2026/21) which had held the same product exempt as ‘fresh’.
The AAR reasoned that the test of eligibility hinges on whether the goods are ‘fresh or chilled’ at the time of supply by the applicant, not at the time of procurement. The applicant had provided no justification or documentary evidence as to how long it takes from harvest to supply, and storage in dry ventilated godowns renders the seeds a dried character. Applying the principle from CBIC Circular No. 163/19/2021-GST that produce ceases to be fresh once ‘intentionally dried to dehydrate including through sun drying’, and noting that the agricultural process itself involves deliberate post-harvest drying before threshing, the AAR concluded the seeds were ‘dried’ at the point of supply. The applicant’s alternative argument under Entry 77 (‘All goods of seed quality’) was also rejected as the specific Entry 71/87 for Heading 1211 prevails over the general Entry 77 for Chapter 12.
- 2026-juristway.com-2637-AAR(Rajasthan)-GST | AAR Rajasthan | RAJ/AAR/2026-27/17 | 25.08.2026