The Ministry of Finance has notified amendments to GST exemptions covering helicopter passenger transport, agricultural warehousing, coffee curing, provident fund services and the grant of toll collection rights. The notification also excludes goods supplied through electronic commerce operators from the exemption available under a specified goods transport agency entry.
Notification No. 07/2026-Central Tax (Rate), dated October 27, 2026, will take effect from November 1, 2026. It amends Notification No. 12/2017-Central Tax (Rate), which governs exemptions for specified services under the Central Goods and Services Tax framework.
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Issued by the Ministry of Finance’s Department of Revenue on the recommendations of the GST Council, the notification introduces several new exemption entries and revises existing descriptions and definitions.
The notification inserts a new item under serial number 15 to cover passenger transportation by helicopter on a seat-share basis where the journey begins or ends at an airport, including a helipad, in any of the specified northeastern states or at Bagdogra in West Bengal.
The states covered are Arunachal Pradesh, Assam, Manipur, Meghalaya, Mizoram, Nagaland, Sikkim and Tripura.
The wording covers a qualifying journey that either embarks from or terminates at an airport or helipad in these locations. Consequently, both endpoints need not be situated within the specified region.
The exemption is expressly linked to helicopter services operated on a seat-share basis. The amendment should therefore be read according to that service description rather than treated as a blanket exemption for every helicopter operation.
A significant change concerns serial number 21A of the exemption notification.
A newly inserted explanation states that the entry will not apply to services provided by a goods transport agency in relation to goods supplied through an electronic commerce operator.
From November 1, services falling within this exclusion will therefore cease to qualify for exemption under entry 21A. Transporters and businesses arranging the movement of goods sold through electronic commerce operators will need to examine the applicable tax treatment.
The amendment is specific to the exemption under this entry. It does not, by itself, prescribe a tax rate or determine the person liable to discharge tax in every transaction. Those questions require examination of the other applicable GST provisions and notifications.
The notification also substitutes the definition of “goods transport agency” in paragraph 2 of the principal notification.
Under the substituted definition, a goods transport agency means any person who provides a service in relation to the transportation of goods by road and issues a consignment note, by whatever name called.
The definition retains an express connection between road transport services and the issuance of a consignment note. The description given to that document is not decisive, since the wording covers a consignment note “by whatever name called.”
Separately, the explanation appearing against serial number 18 is omitted. The notification does not reproduce the omitted explanation, and its effect must be assessed by reading the principal notification as amended.
The service description under serial number 24B has been replaced with:
“Services by way of storage or warehousing of cereals, pulses, fruits, vegetables, and seeds meant for sowing”.
The revised entry expressly identifies the goods whose storage or warehousing is covered. Businesses providing such services will need to assess eligibility against this substituted description from the effective date.
For seeds, the service description specifically refers to seeds meant for sowing. The notification also inserts a detailed definition of “seed” to support the interpretation of the exemption framework.
The new definition extends beyond conventional seeds to include plant material used or intended for propagation or sowing.
It covers seedlings, tubers, bulbs, rhizomes, roots, cuttings, all types of grafts, tissue culture plantlets and other vegetatively propagated material.
The definition also includes seeds of cereals, coarse cereals, pulses, oilseeds, fibre crops, forage and fodder crops, green manures and sugar crops. Seeds of fruits, vegetables, spices, flower crops, ornamental crops and plantation crops, along with planting material, are expressly included.
This wording provides a broader statutory description for interpreting references to seeds within the notification. Eligibility for a particular exemption will nevertheless depend on the conditions and service description of the relevant entry.
A new entry, serial number 54A under Heading 9986, provides a nil rate for services by way of curing coffee supplied to coffee cultivators.
The notification links the meaning of “curing” to clause (d) of Section 3 of the Coffee Act, 1942.
The exemption is framed around both the nature of the service and its recipient. It covers coffee curing services supplied to coffee cultivators, rather than every service associated with coffee processing or trade.
The notification inserts serial number 31AA under Heading 9971 or Heading 9991.
This entry provides a nil rate for services supplied by the Seamen’s Provident Fund Organisation to persons governed by the Seamen’s Provident Fund Act, 1966.
The rate and condition columns both specify “Nil”. The exemption remains tied to the organisation and the class of recipients identified in the entry.
A new entry, serial number 42A under Heading 9973, covers services involving the grant of an exclusive right of way or access, licence and authority to demand, collect and appropriate toll fees.
The exemption applies where the grant is made by the Central Government, a State Government, a Union Territory, a local authority, a governmental authority or a government entity.
The entry addresses the grant of the specified toll collection rights by these bodies. Its wording should be distinguished from the separate question of GST treatment of other services supplied under a toll project.
All amendments under Notification No. 07/2026-Central Tax (Rate) take effect on November 1, 2026.
The changes require particular attention from helicopter operators, goods transport agencies handling e-commerce consignments, agricultural warehouse operators, coffee curing service providers and entities receiving toll collection rights from public bodies.
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