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Voluntary revision of entry, post clearance – New Section 18A of The Customs Act,1962

JM Kishore
Finance Bill 2025: New Section 18A Allows Post-Clearance Entry Revisions; New Rules Under Section 157 to Regulate Process. The Finance Bill 2025 introduces a provision for Voluntary Revision of Entry Post-Clearance under Section 18A of The Customs Act, 1962, allowing importers/exporters to amend declarations after clearance. This necessitates new regulations under Section 157 to define eligibility, correctable errors, and verification processes. Concerns include increased workload for customs officers and potential misuse by traders to reduce declared values post-clearance. Solutions proposed include restricting eligibility, setting revision deadlines, and using AI for risk assessment. The provision aims to balance benefits with potential challenges in revenue collection and administrative workload. (AI Summary)

One of the new provisions in the Finance Bill 2025 mentioned in the  Budget 2025  is the Voluntary Revision of Entry Post-Clearance by importers/exporters. This provision alters the assessment process by allowing importers/exporters  to revise declarations after clearance. Since post-clearance revision is not currently defined in existing regulations, a new regulation under Section 157 may be required to address:

Scope

  • Define who is eligible to file a voluntary revision (e.g., only importers/exporters with a clean compliance history? Or all can do that?). Sub-section (5) provides a few cases  where revision of entry is not permitted.
  • Specify types of errors that can be corrected (e.g., clerical errors, HS code misclassification, value misdeclaration?).

Eligibility Criteria

  • What are the  conditions under which voluntary revision can be made need to be notified vide Regulations.
  • Should revision be allowed only once per Bill of Entry? Clarity may be needed.
  • What level of misdeclaration (e.g., % of variation in value/duty) qualifies for voluntary correction of entry?

Verification & Compliance Mechanism

  • Officers will need a clear process to verify the correctness of revised declarations.
  • Should revisions be automatically accepted if within a certain threshold, or should every case be manually verified?
  • If revised entry reduces duty payable, how will Customs prevent misuse?

Does the provision impact the work load for Customs officers?

Likely. It may  increase the assessment work load  on officers . Allowing post-clearance revision means officers may need to reopen and reassess documents after clearance, leading to higher workload. It is not clear how systems can integrate this aspect. Teething issues likely to arise.

Possible  Misuse?

 Some traders may use the revision process strategically to reduce declared value after clearance, impacting revenue.

In terms of Section 18A(4)(a), bills when opted for revision may be selected primarilyon the basis of risk evaluation throughappropriate selection criteria. It indicates that not all revisions need to be verified by Customs. It may be better that such cases which are not picked up for revision may atleast be allotted to Post-clearance Audit.

Issues in revenue collection :

  • If revisions lead to refund claims due to corrections, the customs department might face higher refund processing workload.
  • Revenue collection could become more uncertain as the final duty payable may change even after clearance.
  • Regulations may also to specify that an automated AI-based risk-assessment tool could be integrated into ICEGATE to flag genuine revisions vs. fraudulent ones.

Balancing the Benefits vs. Increased Workload

Possible solutions to reduce assessment burden:

  • Restrict eligibility: Allow revisions only for genuine clerical errors, not major duty reductions.
  • Time limit for revisions: Set a deadline (e.g., 15 days from clearance) to avoid indefinite re-assessments.
  • Threshold-based auto-approval: There may be a stipulation of quantum , either the duty amount or a condition that If a revision affects duty by less than 5% so as to be  automatically approved without officer intervention or otherwise.
  • Introduce an AI-driven review mechanism: Use risk assessment algorithms to flag high-risk revisionsfor manual review.

Will new Regulations Under Section 157 be needed?

Yes, because the voluntary revision of entry is likely to create a new procedural right for importers /exporters and needs structured eligibility, verification, and compliance mechanisms.

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