Indong Tea GST Investigation Closed with No Liability

Authority: Deputy Commissioner of State Tax, Bureau of Investigation (South Bengal), H.Q., Government of West Bengal
Nature of Action: Report on Closure of Investigation Process upon inspection initiated under Section 67(1) of West Bengal Goods and Service Tax Act, 2017 read with rule 139(1) of West Bengal Goods and Service Tax Rules, 2017
Inspection Date: 21-11-2025 at the company's registered office/place of business
Initial Disclosure: Company had intimated stock exchanges about the inspection on 22-11-2025 (BSE Acknowledgement No- 11459464)
Report Receipt Date: 17.07.2026 per DIN No. WBGST/1004/220426/002LiL and Memo No: 03/BI(SB)/LTU/A03/26 dated 22.04.2026

During the inspection, the Registered Taxable Person (RTP - Indong Tea) was alleged to have:

Failed to provide details of exempted goods (lentil, rice, jute) for periods 2024-25 and 2025-26
Produced only sample copies of bill of supply but failed to produce transport documents during inspection
Booked income under "supply of Farm labour" while issuing bills of supply for labor services (digging drain, leveling of soil, etc.) and reimbursement of tractor charges

Notice for personal hearing was issued
Mr. Sumit Nishania, authorized representative, appeared for personal hearing and submission of documents on 13/01/2026, 05/02/2026, 07/02/2026 and 26/02/2026
Exempt Supply Declaration in GSTR 9 and GSTR 3B:
2022-23: ₹21,25,453/-
2023-24: ₹20,17,210/-
2024-25: ₹7,77,54,219/-

Ld. A/R informed that the company supplied tea (HSN 0902) charging tax at 5% (taxable supply) and also supplied exempted items (jute, white raw rice, red lentils)
Submitted copies of Bill of Supply, consignment note and purchase documents which were verified by authorities
Exempted supply amounts matched with Annual Financial Statement - issue reconciled

Company entered "Plantation Development Works Agreement" on 14/02/2023 with Vista Solar Energy Limited (GSTIN: 19AABCP9585F1ZX)
Agreement covered Indong Tea Estate, P.O. & P.S. Matelli, Dist Jalpaiguri
Scope of services by Vista included:
Uprooting of Tea Bushes (by JCB/Manual)
Uprooting of Shade Trees
Land Preparation
Drainage
Tea Planting
Shade Tree Planting
Fencing
Vista was allowed to use labours available at tea estate and JCB/tractor owned by the company
Company charged Vista ₹18,600/- per Hect for JCB/tractor use and issued Bill of Supply

Company argued that leasing of JCB for tea garden development is exempted as per Entry No. 54 of Notification No. 12/2017 - Central Tax (Rate) dt 28.06.2017
JCB was used as agro machinery for "agricultural produce" (green tea leaves)
Supply of leasing services of JCB/tractor for agricultural activity qualifies for exemption

Both points raised in the inspection report were reconciled during the hearing process
No tax liability established on these matters
Report for closure of investigation process submitted

There is no material impact on the financial, operations and/or other activities of the Company upon issue of the aforementioned Report.