Classification of supply— The moot issue before us to decide upon is whether the tea leaves of the various qualities, which is precisely black tea, procured in bulk either from public tea auctions or directly from manufacturers of tea in 50 Kg bags, after undergoing various stages of the processing as detailed above, by the appellant's client i.e. Unilever, for storage in the warehouse owned by the appellant are agricultural produce or otherwise.
the appellant that the advance ruling authority had made the decision on wrong facts, as it was held by the advance ruling authority that the appellant warehouse had been used for the storage of the procured bulk tea after blending and packing by Unilever. The advance Ruling authority denied the benefit of Serial No. 54 of Exemption Notification No. 12/2017-CT (Rate).
The said exemption granted vide the above notification is provided to the storage and warehousing services when provided in relation to the agricultural produce.
We do not find any reason to interfere with the ruling given by Authority for Advance Ruling.Nutan Warehousing Company Pvt. Ltd.  7 TAXLOK.COM 018 (AAAR-MAHARASHTRA)