Warehouse services—claim of benefit of exemption—In the instant application, question before authority is that “Whether the supply of warehouse services used for packing & storage of tea, was/is exempted vide Serial No 54(e) of Notification No. 12/2017- Central tax (rate) or otherwise?”
Held that—Even if we assume that in the beginning they are bringing raw tea leaves or may be semi processed tea leaves which they have not clearly specified to the godown, they are under taking further processing and manufacturing of the same as per processes given above and are finally storing manufactured tea as per details given by them self above which finally culminates into packing of Lipton Pure and Simple 100s tea bags. This activity of M/s. Unilever of processing of raw tea leaves into tea results in emergence of a new product having distinct name i.e. Tea, which has distinct name, character and use i.e. Lipton Pure and Simple 100s Tea bags. As such the impugned activity is a 'manufacture' as defined in clause (72) of section 2 of the GST Act - The final product considering various processes undertaken by M/s. Unilever cannot be considered as Agricultural Produce.

The goods being stored in the applicant's godown are not agricultural produce as per definition given in Notification No.12/2017-Central Tax (Rate) dated 28th June, 2017 and the same is reiterated by Board Circular No. 16/16/2017-GST issued under F No. 354/173/2017-TRU dated 15.11.2017.
Green Tea Leaves are falling in the definition of Agricultural Produce and Tea is not falling in the definition of Agricultural produce.
Ruling—Exemption provided in serial no. 54 to Notification No, 12/2017 Central Tax (Rate) is not applicable to the activity carried by the company.[AUTHORITY FOR ADVANCE RULINGS MAHARASHTRA] [2018] 2 TAXLOK.COM 293 (AAR-Maharashtra)