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Exemption is not available on rendering services such as loading, unloading, packing, storage or warehousing of imported agriculture products including wheat, to any importer or trader.

Classification of service— In the instant case, applicant is providing services such as loading, unloading, packing, storage or warehousing of Agricultural produce including wheat that are being imported by any importer or trader through the Karaikal Port. Applicant seeking an Advance Ruling on “Whether exemption provided in SI.No.54(e) under Heading 9986 of GST Notification No.12/2017-Central Tax (Rate) dated 28.06.2017 while rendering services such as loading, unloading, packing, storage or warehousing of imported agricultural products including wheat, to any importer or trader.' Held that— the applicant is providing the services of loading, unloading, packing, storage or warehousing in respect of the 'wheat' which is procured from the farmers from the foreign country and after getting imported into India at Karaikal Port is destined to importer's factory for further processing and it is not destined to the primary market as required for the services to be classified under sl. No. 54 (e) of Heading 9986 of the said exemption Notification. Therefore, the said services rendered by the applicant in the instant case are not eligible for the exemption under the said Notification.
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