माल और सेवा कर परिषद Goods & Se₹vices Tax Council

Q1) Whether Psyllium Seeds (Isabgol) 12119013 brought by cultivators/farmers to an Agricultural Produce Market Committee (APMC) and sold through the auction mechanism in their natural, raw and unprocessed form — without undergoing drying, dehydration, freezing, grading, polishing, crushing, milling, roasting, chemical treatment or any other processing activity — are classifiable under Tariff Item 12119013 and are accordingly exempt from levy of GST under Entry No. 87 of Notification No. 10/2025 -Central Tax (Rate) dated 17.09.2025, as amended from time to time? 

Ans.- Yes, the Psyllium Seeds (Isabgol) brought by cultivators/farmers to an Agricultural Produce Market Committee (APMC) and sold through the auction mechanism in their natural, raw and unprocessed form — without undergoing drying, dehydration, freezing, grading, polishing, crushing, milling, roasting, chemical treatment or any other processing activity — are classifiable under Tariff Item 12119013. However, the Psyllium Seeds (Isabgol) supplied by the applicant can not be said to qualify as "fresh" Isabgol seeds and are not exempted under Entry 87 (HSN 1211) of Notification No.10/2025-Central Tax (Rate) dated 17.09.2025 as "Plants and parts of plants (including seeds and fruits) of a kind used primarily in perfumery, in pharmacy or for insecticidal, fungicidal or similar purpose, fresh or "chilled." The same are liable to tax @ 5% under Notification No. 09/2025-CT dt 17.09.2025. 

Q2) Whether threshing undertaken by cultivators for separating Psyllium Seeds (Isabgol) from the harvested crop constitutes merely a harvesting activity and not processing or manufacture for the purpose of classification and exemption under GST? 

Ans.- We do not find this question fit for pronouncement of ruling as it do not fall within the ambit of Section 97(2) of the GST Act.

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(1) Whether GST rate of @5% or 18%is applicable on the job work services of offset printing provided by the applicant on Kraft Paper and Duplex Paper supplied by the Corrugated box manufacturer/Packaging Industries w.e.f. 22.09.2025, in terms of Notification No.15/2025-Central Tax (Rate) dated 17.09.2025? 

(2) Whether paper cutting charges, paper sheet loading charges, bundle unloading charges and plate charges shown separately on Sale invoice, are ancillary to and form part of the principal supply of printing services, and whether the same GST rate applicable to printing service would apply to such charges?

(i) What is the correct classification and applicable GST rate on Washing/Laundry Soap (in BAR or CAKE form) used for washing clothes or toilet purposes as per Notification No.09/2025-Central Tax (Rate) dated 17.09.2025 effective from 22.09.2025? 

(ii) Whether such Washing/Laundry Soap for clothes and crockeries falls under the same GST rate and classification as Toilet Soap or under a separate tariff heading? 

(iii) What are the applicable 8 digit HSN codes and Rate of GST for Washing Soap, Laundry Soap, Crockeries Soaps and Toilet Soap under GST law?

1. Whether the product, in question, Ophthalmic Binocular Surgical Microscope shall merit classification under the CTH 9018 of the Custom Tariff Act, 1975 or otherwise.

 2. Whether the goods Ophthalmic Binocular Surgical Microscope fall within the Sr.No.483 of Schedule-I of Notification No. 9/2025-CT (Rate) dated 17.09.2025 or otherwise.

Whether Notification 13/2020-CT (e-invoicing) applies where a registered parent/guardian/enterprise furnishes GSTIN and pays consideration; held applicable to genuine B2B supplies, but Authority declined to endorse the premise that every fee-paying registered person is automatically the "recipient" under Section 2(93)(a), since that determines place of supply (outside Section 97(2)); ITC eligibility in recipient's hands held independent of supplier's e-invoicing obligation.

GST rate on job work services for handicraft goods (5% concessional rate held applicable only while applicant is registered and goods are genuinely handmade); classification of resin statues (held under HSN 3926, not 9703 - not "original sculptures"); exemption for deities of marble (Ch. 68) and wood (Ch. 44) under Entry 124 of Notification 10/2025-CT(R).

Whether the seeds qualify as "fresh" (NIL, Entry 87 of Notification 10/2025-CT(R)) or "dried" (5% GST, Entry 71 of Notification 09/2025-CT(R)); ruled dried/taxable @5% - storage in dry/ventilated godowns held to amount to drying; Gujarat AAR ruling in Akshar Traders distinguished as non-binding under Section 103.

Whether the seeds qualify as "fresh" (NIL, Entry 87 of Notification 10/2025-CT(R)) or "dried" (5% GST, Entry 71 of Notification 09/2025-CT(R)); ruled dried/taxable @5% - storage in dry/ventilated godowns held to amount to drying; Gujarat AAR ruling in Akshar Traders distinguished as non-binding under Section 103.

Whether the seeds qualify as "fresh" (NIL, Entry 87 of Notification 10/2025-CT(R)) or "dried" (5% GST, Entry 71 of Notification 09/2025-CT(R)); ruled dried/taxable @5% - storage in dry/ventilated godowns held to amount to drying; Gujarat AAR ruling in Akshar Traders distinguished as non-binding under Section 103.