TMI Blog2005 (12) TMI 203X X X X Extracts X X X X X X X X Extracts X X X X ..... ssee is carrying on business of manufacturing/processing certified seeds as well as labelled seeds for Bajra crops had filed its return of income for assessment year 1998-99 declaring an income of Rs. 2,68,24,810 on 2-10-1998. During the course of assessment proceedings, the Assessing Officer noticed that the assessee's turnover of certified seeds was Rs. 2,10,19,072 and of labelled seeds was Rs. 60,01,92,742. 3.2 Since the assessee was manufacturing/processing certified seeds it had to procure a Certificate from Gujarat State Seed Certification Agency, a State owned Agency to supervise and control the production and manufacturing of certified seeds; had to provide foundation seed to farmers in addition to know-how, etc. and for that purpose was to get itself registered as co-producer. In this system of carrying on the business, the assessee was definitely to incur expenditure. It was, in view of these facts that the assessee had claimed the total processing charges at Rs. 50,80,976. 3.3 The Assessing Officer, considered that the sale of certified seeds (at Rs. 2,10,19,072) was only 25.88% of total sales, i.e., 25.88% of sales of certified seeds amounting to Rs. 2,10,19,072 + l ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... aimed any expenditure with relation to certified seeds or not. The issue is, therefore, remanded back to the file of CIT (Appeals) with the directions that the same may be decided afresh in accordance with law and with a speaking order after allowing the assessee a proper opportunity of being heard and keeping in view the final outcome of Revenue's appeal for the assessment year 1997-98. 6. Coming to issue involved in ground No. 1, the ld. DR has supported the order of the Assessing Officer, after relying on the order of the ITAT Ahmedabad Bench 'A' in assessee's own case (ITA No. 1110/Ahd./2004) for the assessment year 2000-01, dated 29-10-2004 wherein the Tribunal rejected the assessee's claim of deduction under section 80-I by observing as under:- "5. After considering the rival submissions and going through the material on record, we find that the assessee is engaged in processing and distribution of agricultural seeds. The assessee purchases and supplies foundation seeds to growers and the same are cultivated by agriculturists in their fields and they are offered to assessee to purchase. Assessee purchases the seeds subject to his germination test. In case seeds are not up ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... entitled to claim deductions under sections 80-I and 80-IA of the Act, which has not been done by assessee in this case. In this case seed is raw material and end product is seed. Assessee is not purchasing food grains but only seeds are being purchased from growers so there is no question of any genetic or chemical irreversible change in raw material. So the ratio of the decision of Hon'ble Supreme Court in the case of Krishi Utpadan Mandi Samiti v. Pilibhit Pantnagar Beej Ltd. is of no help to the assessee. Various decisions based on the decision in the case of Krishi Utpadan Mandi Samiti v. Pilibhit Pantnagar Beej Ltd. also do not help the assessee. Even the contents of partnership deed of assessee firm, agreement entered by the assessee with agriculturists docs not help the assessee. The details of salary and process render no help to assessee as far as allowability of deduction under sections 80-I and 80-IA is concerned. It is only paper work. In view of the above discussion, we are of the view that no interference from our side is called for and the appeal is liable to be dismissed. We order accordingly." 6.1 The ld. DR further submitted that the seed is grown in the fields ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... allowing the deduction under section 80-I and under section 80HHA of the Act having been confirmed by the Hon'ble Apex Court, there is no necessity to enter into the arguments as to which of the Tribunal's order (in assessee's case) be followed. According to him, it is well-settled law relating to precedent and judicial proprietary that facts and circumstances remaining the same, it is the decision of Jurisdictional High Court or of the Apex Court, which has the binding precedent and is to be followed - irrespective of conflicting decision of the Tribunal or High Courts - if there is decision of Apex Court; and since in the present case, the issue is covered in favour of Assessee and against the Revenue by the decision of Hon'ble Supreme Court of India in the case of Navbharat Seeds (P.) Ltd. The order of the CIT (Appeals) on this point may be confirmed. (ii) Further, the ld. Counsel for the assessee, has supported the order of the CIT (Appeals) by relying on the following decisions:- (a) Decision of ITAT Ahmedabad Bench 'D' in assessee's own case for assessment years 1992-93, 1993-94 and 1995-96 in ITA Nos. 399 to 401/Ahd./1999 (Alongwith CO Nos. 49 to 51/Ahd./2002), dated 1-6 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... re tested in the Government Notified Laboratory and seed lot is released as certified only if the lots meet the standards. Processed seed then has to be treated with prescribed doses of poisonous chemicals by putting both the chemicals and the seed in seed F treating drums and seed treatment process is carried out which coats each and every seed with poisonous chemicals which protects the hybrid seed from diseases and insects even after sowing. It was pleaded that this process is mandatory for getting the seed certified. Processed and treated seed is then packed in cloth bags having designs as approved by the Seed Certification Agency. All this process has been explained in the arguments by the ld. AR of the assessee in para 6.2 of the impugned order. After considering these submissions, the CIT(A) relying on the following decisions has held that the assessee is entitled to deduction under section 80-I as the process carried out by the assessee meets the requirements of section 80-I. (i) Tarai Development Corpn. v. CIT 120 ITR 342 (All.) (ii) ITO v. Navbharat Seeds (P.) Ltd., ITAT, Ahmedabad. Vide its order dated 29-11-1989 in appeal No. ITA 2816/Ahd./1986. (iii) CIT v. EID P ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... pplied to the DR. There has been no request from the side of the Revenue to be heard in respect of the said detailed note furnished on behalf of the assessee. In other words we proceed to record that the facts stated in the note remain unchallenged and are the accepted facts between both the parties. We now proceed to state these undisputed facts: 'Navbharat Seeds Private Limited, a company registered on 23rd April, 1981 under the Companies Act, 1956 having its registered office at 4, Sarvodaya Commercial Centre, Salapose Road, Ahmedabad. The company is engaged in production, processing and marketing of various hybrid seeds of different crops such as hybrid bajra, hybrid cotton, hybrid jowar, hybrid maize and hybrid castor etc. The activities of the company comprises of the following:- (1) Production of hybrid seeds; (2) Processing of hybrid seeds (3) Testing and quality control (4) Marketing of seeds. All the above activities are conducted as per the 'Indian Minimum Seeds Certification Standards' stipulated by Central Seed Certification Board, Department of Agriculture and Co-operation, Ministry of Agriculture, Government of India. The company is producing, processing ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and tested at Government Seed Testing Laboratories for germination, physical purity and genetic purity. If this seed conforms to the standards prescribed by the Government of India in the Minimum Seed Certification Standards then it will be certified seed. (2) Manufacturing Process: Seed processing sequence and equipment: (a) Moisture meter: Testing moisture content to decide need for drying. (b) Air screen cleaner: to clean the seed. (c) Gravity separator: To upgrade the quality of seed. (d) Slurry treater: To treat the seed with chemicals for protection-against insects and micro-organisms. On receipt of the raw seed from the fanner's field the seeds are dried and tested for moisture content. Afterwards the seeds are cleaned on Air Screen cleaner. This process remove immature seed, dust particles, plant materials, offsize seed diseased or insect damaged seed etc. After basic cleaning the seeds are upgraded on Gravity separator to improve the quality of seed by using weight component difference between seeds. The seed then treated with 1% mercurial fungicides and DDT in Slurry Seed Treater. This is done to protect seed against seed borne and soil borne micro-organisms. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ub-producer shall set apart the required area of levelled, fertile land with facilities for healthy seed production. 5. Main producer will provide male and female foundation seed for this programme to the sub-producer, which is to be used only for the above referred seed programme. 6. Sub-producer shall pay for the expenses for land preparation, irrigation, sowings, interculturing, fertilizers, plant protection, pesticides, rogueing, cross pollination and other expenses. 7. Main producer will provide guidance by technical personal to maintain the purity of the seed, and instructions from the seed certification agency shall be observed and implemented by the sub-producer and accordingly, rogueing and removal of selfed bolls would be arranged and paid for by the sub-producer. 8. Sub-producer will co-operate and follow the instructions given for maintaining the purity of the above referred seed production, by the Seed Certification Agency and officials of the main producer. 9. Sub-producer will bring the seed of cotton at his cost for ginning and arrange for ginning and grading under supervision of main producer. 10. 5 samples each of 150 grams will be drawn from the seed ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ivity of marketing the seeds through its distributors and dealers. The activities of the company are more or less identical to those as considered by the Allahabad High Court in the case of Tarai Development Corpn. The distinguishing feature sought to be brought out by the learned DR does not appear to be correct. The other arguments advanced by the DR are also not of any avail vis-a-vis the case of the revenue since these run contrary to the various other decisions relied upon by the assessee's counsel including those of the Tribunal. 11. In the final analysis we uphold the order of the CIT(A) vis-a-vis the claims of the assessee under sections 80HHA and 80-I. 12. The appeal is dismissed." (iii) With regard to the decisions of Hon'ble Supreme Court relied upon by the ld. DR, the ld. Counsel for the assessee had submitted that the same been distinguishable both in facts and law, were not applicable to the present controversy. (iv) It was, further submitted that so far assessee's case was concerned, the final product, i.e., certified seed as well as in labelled seed, was different article or thing, then the raw-bajra because of the treatment with chemicals which had rendered ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ut on the same time, the Hon'ble Tribunal has, further held that a decision on these particular facts and on consideration of the law prevailing at the relevant time can be deviated from it, if some new facts are brought on record or some more cases of higher Courts on the subject has come to its notice. The relevant part of the order as contained in paragraph Nos. 5 to 11 which reads as under:- "5. It is true that a judicial officer including the Tribunal would not be justified or has any right or jurisdiction to come to a conclusion entirely contrary to or different from the one-reached by it on the same facts and if that be allowed to happen that will not sake the confidence of the public in judicial procedure as such, it would be destructive of the institutional integrity itself. The Sayaji Iron Engg. Co.'s case decision of the Gujarat High Court is however of no much help in these cases. Firstly, because the observations were vis-a-vis assessee's own case in earlier year whereas the present assessees are different one; secondly, because Sayaji Iron Engg. Co.'s case was a case of a different view taken on facts, that too on same facts whereas in present cases the question ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d no question of law arose which could be directed to be referred under section 66(2) of the Income-tax Act.' 8. Again see in the case of CIT v. Brij Lal Lohia Mahabir Prasad Khemka [1972] 84 ITR 273 the Supreme Court at page 277 observed as under: 'The fact that in the earlier proceedings, the Tribunal took a different view of those deeds is not a conclusive circumstance. The decision of the Tribunal reached during those proceedings does not operate as res judicata. As seen earlier there was a great deal more evidence before the Tribunal during the present proceedings, relating to those gift deeds.' 9. The Supreme Court decision in the case of Indian Oil Corporation Ltd. relied upon by the ld. counsel of the assessee is also in our opinion, of no help to the assessees. In this case, the Supreme Court observed 'That the Division Bench of the High Court in Municipal Corporation was clearly in error in taking the view that the decision of this court (Supreme Court) in Ratnaprabha was not binding on it. In doing so, the Division Bench of the High Court did something which even a later co-equal Bench of this Court did not and could not do. The view taken by the Division Bench o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ate to the new development and also because each year and each assessee is a separate year and a separate assessee and the principle of res judicata and estoppels did not apply to income-tax proceedings even though the department is one and also because in the earlier order some of the decisions of Supreme Court and the High Court were not considered." 10. After having considered the aforesaid decision and also other decisions on this point, we are of the opinion that so far as both the legal propositions are concerned, there is no dispute, but coming to the binding nature of decision of co-ordinate Bench or of the same Bench, we are of the opinion that this theory is applicable only if, not only the facts and circumstances of the case must remain the same, but the pleadings must also be the same and it is so because it happens many a times that in some cases or at earlier occasion one may not have been able to plead properly or may have failed to bring to the notice of the appellate authority or Tribunal or Court, the latest provisions of law or decisions having binding strength because in such cases, it is the later provision of law or decision which will prevail. If at a later ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... .) Ltd. and Pilibhit Pantnagar Beej Ltd., are of the opinion that the facts of assessee's case are similar to the facts in those cases as the appended Annexures 'A' 'B' of this order, will reveal. 14. Before coming to the final conclusion we would like to consider both the decisions of the Hon'ble Supreme Court relied upon by the assessee - copies of which have been placed in assessee's paper-book and, therefore, we proceed to consider the same. (i) Decision in case of Pilibhit Pantnagar Beej Ltd.: (a) Facts of this as have been revealed from the order of the Hon'ble Supreme Court were that UP Krishi Utpadan Mandi Adhiniyam, 1964 (hereafter referred to as 'Adhiniyam') was enacted to regulate sale and purchase of agricultural produce. (b) Section 6 provided for declaration of Market area and sections 9 and 10 prohibited business of specified agricultural in such market area without licence. Section 2(a) of this Act, specified (agricultural produce) and Schedule appended to Adhiniyam provided all items covered as agricultural produce. (c) Section 17(iii) of the Adhiniyam provided for imposition of market if on the transaction of such specified agricultural produce in the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Method of Seed Production: 3.1 The company purchases breeder seed from the Agricultural Universities and then produces the next stage, i.e., foundation seeds. These foundation seeds are given to contract farmers for further production to certified seed. This certified seed is sold to trade and subsequently to farmers. Foundation Seed is the progeny of Breeder Seed and certified seed the progeny of Foundation Seed. 4. Procedure of production: 4.1 Purchase of breeder seeds from universities. (Rule 14(a)). 4.2 Classification of foundation seed from breeder seed. (Rule 14(a)). 4.3 Giving foundation seed to contract farmers. (Rule 14 c)). 4.4 Registration of the contract farmers with the State Seed Certification Agency and payment of registration and inspection charges to the agency. (Rule 6(d) Form I). 4.5 Sowing the foundation seed by the contract farmer in his field. 4.6 Inspection of the farmer's field by an inspector of all the State Seed Certification Agency, at least two times during the growth of the crop. (Rule 6(k)). 4.7 Submission of final field report by the State Seed Certification Agency, inspector stating that the crop meets the standards or rejecting ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... asonings were adopted lo hold that the transaction of seeds do not attract market fee namely (a) that the definition of agricultural produce includes items specified in Schedule and that wherever it was intended to separately cerealised seeds, they have been distinctly found mentioned in the Schedule and that wherever the Schedule does not include seeds specifically in the serialised item such seeds are not specified agricultural produce and (b) on the process of coating and applying insecticides, other chemicals and poisonous substances the basic character, i.e., its consumption as food by human being or animals is irretrievably lost and that such commodity is distinct from foodgrains. The decision of the State Government does not take into account the first reasoning and treats only that commodity as seeds which is treated with chemicals and that the action, in our view, is apparently and palpably wrong. It is to be noticed that the farmers are paid prices on the certified seed only after its certification and that the entire quantity of such seeds is chemically treated and is thus a distinct commodity as certified seeds. It was denied that the first respondent purchased wheat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lture in meeting, dated 16-5-1998 also support trader's stand.' I.A. No. 3 of 2001 is filed by the first respondent for seeking permission to place on record a letter dated 19-1-2000 annexed as Annexure A which is very important for the final adjudication of the case. The said I.A. be taken on record. By the said I.A., the first respondent sought to place on record a letter dated 19-1-2000 addressed by the Principal Secretary, Government of Uttar Pradesh to the Commissioner, Trade Tax Department, Government of Uttar Pradesh directing that instructions be issued to the taxation officers that when the growers or the distributors, seed certification machinery sell the seeds in sealed containers after producing themselves after certification along with the tag of the Uttar Pradesh Certification Agency affixed as under the Central Seed Act, 1966 then in such circumstances, no liability of purchase tax is attracted under section 3 AAAA(4). We have perused the communication dated 19-1-2000 marked as Annexure A. The judgment in the case of State of Rajasthan v. Rajasthan Agricultural Inputs Dealers Association was heavily relied on by the learned senior counsel appearing for the first ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... appellants will not be of any assistance in deciding the factual disputes involved in the instant case. In our view, the High Court has correctly applied the above judgment. This Court held that no market fee could be levied by the State of Rajasthan on seeds on the ground that a seed was distinct from foodgrains inasmuch as they were not fit for human consumption. The ratio decidendi of the above decision is squarely applicable to this case wherein the appellant seeks to give a wide connotation to the words in the Schedule. In our opinion, that giving a wide interpretation is not possible and as Wheat Seed is not included in the Schedule, the Mandi Samiti is not allowed to levy a market fee on purchase. As the Mandi Samiti plays no role in the trade of the respondent's seeds, it may not be allowed to levy the market fee. It is also not in dispute that the Breeder Seeds are allocated by the Ministry of Agriculture or by the Universities to the various seed producing agencies and companies who multiply the breeder seeds into foundations seeds. It is also very useful to refer hereunder the process by which the seed is manufactured under the Seeds Act and the Seeds Rules: "(i) Se ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the seed has been chemically treated or not and the levy of market fees. Since the seed is a separate commodity from grain, the same is not covered under Schedule 1 of the Adhiniyam and as such no market fee is leviable over the sale and/or purchase of the same. We are, therefore, of the view that the seeds are not specified agricultural produce under the provisions of the Act and, therefore, the business of purchase and sale of seeds under the supervision of Seed Certification Agency established under the Act is not a business of sale and purchase of specified agricultural produce and as such the first respondent is not required to pay the market fee or to take out a licence. We are also of the view that the respondents have grossly erred in ignoring the law settled by this Court in the case of State of Rajasthan v. Rajasthan Agricultural Inputs Dealers Association under Article 141 of the Constitution in demanding market fee on seeds. Since the processing of wheat resulting in loss of its basic characteristics of being cereal, it cannot be subjected to levy as agricultural produce since the purchase by the respondent is for the purpose of growing seeds, no levy is permissible ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ) Ltd is a brief order and has referred to a note considered by the Tribunal. We are of the opinion, it is necessary to consider the order of the Tribunal, relevant part of which has been reproduced in paragraph No. 7(ii)(c) of this order, also. (iii) After careful consideration of the order of the Tribunal we are of the opinion that, any cereal, if after treatment with poisonous chemicals gets rendered unfit for human consumption is altogether a different article or a thing, then the original cereal and production of seed being in the same way, the seed so produced also become unfit for human consumption and ceases to be cereal, meaning thereby that the seed (final product), though original cereal remains one of the ingredients, is an article or thing different from the basic cereal and, therefore, the method used therein is nothing, but manufacturing or production of seed, an altogether different article or thing, rendering the assessee entitled to deduction under section 80-I of the Act. 16.(i) After giving our thoughtful consideration of the totality of the facts and circumstances of the case and various decisions, we are of the opinion that the issue involved in this groun ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng, which yields the polished diamond, cannot be said to amount to manufacture or production of an article or thing, for the purpose of obtaining the benefit of deduction under section 80-I of the Income-tax Act, 1961. In our opinion, the facts of the case before the Hon'ble Supreme Court were quite different. There was no difference in rough diamonds and final polished diamonds, whereas in case before us the final product, i.e., the seed; which, admittedly, is always unfit for human consumption and ceased to be 'cereals' which is fit for human consumption and cereals is, always, definitely a new article or thing and, therefore, the decision relied upon by the ld. DR is no help to the Revenue. (iii) Decision of Hon'ble Supreme Court in the case of Sacs Eagles Chicory v. CIT [2000] 255 ITR 178. In this case, the Hon'ble Supreme Court has held that the only processes recorded by the Appellate Tribunal being that the chicory roots were roasted and that they were powdered, the activity of the assessee did not satisfy the test laid down in Aspinwall Co. Ltd. v. CIT [2001] 251 ITR 323 and did not amount to manufacture and the assessee was not entitled to the special deductions un ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... seeds. of Hybrid issued by Seeds Gujarat State (3) Testing and (3) Testing and Seed Certi fi- quality Quality cation Agency. control. Control (4) Marketing (4) Marketing of seeds. of Seeds Are the basic and essential for all seed producing compa nies. 2. All the above Rules and Laws The procedure activities are prescribed by is narrated in conducted as Govt. remain the enclosed per the same for all certificate. "Indian seed producers. Minimum Seeds Certification Standards" stipulated by Central Seed Certification Board, Department of Agriculture and Co-opera- tion, Ministry of Agriculture, Government of India. The company is producing, processing and marketing certified seeds. Gujarat State Seeds Certifi- cation Agency inspect the seed production field, pr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sub- foundation seed producers. The so supplied. foundation seeds are distributed to contract growers free of cost or at concessional rate or at cost depending on contractual agreement. 3.3 Actually it The registration The mandatory is not a sale but procedure of requirement of only an account seed plots with submission/ adjustment for State Certifi- verification joint venture cation Agency of source of of seed is same for foundation seed production. everybody. We is narrated in Each and every have to submit Para 1 of the seed plot so before the Seed enclosed organized is to Certification certificate be registered Agency with of GSCCA. with Government empty containers Seed Certifi- and tags to cation Agency establish, the in the name of authentic source Company as main of foundation producer and seed supplied farmer as sub- to growers. producer. 3.4 (c) Technical We have a very This is narrated in guidance: After large team of on the first page distribution of experienced ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Certification Standards then it will be certified seed. 4.(2)Manufacturing Process: Seed processing sequence and equipment: 4.1(a) Moisture We have moisture meter: Testing meter. Our area moisture content of Bajra Seed to decide need production i.e. for drying. Gujarat and Andhra Pradesh fall in Semi- Arid Zone of Climate. The moisture content of Bajra Seed produced in this Zone is naturally controlled. Due to this reason, State Seed Certification Agency also do not conduct moisture test for every samples of seed produced in this area. However we do test moisture in some of the seed lots. 4.2 (b) Air We use This is a mandatory screen cleaner: mechanised ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sieves and fungicides and air blower. The DDT in Slurry good seeds having Seed Treator. good vigor and This is done to germination protect seed capacity is against seed separated and then home and soil subjected to borne micro- treatment of organisms. poisonous pesticides, which boost the capacity of seed to resist the attack of pest and disease in the field of farmers, who sow the seed for commercial cultivation. 6. In case of This treatment hybrid cotton is applicable seed raw hybrid in case of seed is treated cotton seed in a tank with only. concentrated H. This process will dissolve fuzz, lint and wax of seed coat. After that with lime solution the seed is neutralized. These processes will make the seed free flowing. The same seed is then run on Air Screen Cleaner, Gravity separator and slurry treator to improve the quality of seed. 7. (3) Testing and quality ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ation of the officer is fixed with the container. The treatment This is a mandatory of poisonous requirement by law, pesticide is which is described mandatory and under point No. 3 hence this of the enclosed warning is also certificate. compulsory to be printed in RED ink on each container 9. The hybrid Bajra being our seeds are marked main crop, we by the company possess strong mainly in the distributors/ State of Gujarat dealer network and Maharashtra in Haryana, through its Rajasthan, distributors/ Gujarat and dealers network. Maharashtra. ----------------------------------------------------------- ANNEXURE 'B' (see para. 13 of the Order) ------------------------------------------------------------ Pilibhit Pantnagar Beej New Nandi Seed Corporation Ltd. Ors. ------------------------------------ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on to the agency. to the agency. The farmers The farmers sow these sow these foundation seed foundation seed which which again supervised by again supervised by the the Agency. This crop is Agency. This crop is again germinated under the again germinated under strict supervision of the the strict supervision agency and once again the of the agency and once lots rejected are not taken again the lots rejected back from the farmers. After are not taken back from harvesting the approved the farmers. After standardised certified harvesting the approved seeds, are brought to standardised certified processing plant of the firm. seeds, these lots are Only those lots, which fumigated for preser- are not sold immediately vation under the samples and are to be stocked of each lot is tested for longer period, are in the laboratories of fumigated with Cell Seeds Certification phose/Quick phose for Agency. The rejected lots preservation. The samples and los ..... X X X X Extracts X X X X X X X X Extracts X X X X
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