If your business is running under the Manufacture and Other Operations in Warehouse (No. 2) Regulations, 2019 (MOOWR) and you’re planning to exit, you’ll need to go through a process called debonding.
The word may sound complicated, but it simply means closing your bonded warehouse licence and manufacturing permission, and paying any customs duty on the goods you want to keep in India. With some planning, it’s a smooth process and nothing to be worried about.
What Exactly is Debonding under MOOWR?
Under MOOWR, you can:
- Import raw materials and machinery without paying duty upfront.
- Pay customs duty only when goods are cleared into the Domestic Tariff Area (DTA).
- Export goods without paying duty on the imported inputs used.
When you debond, you’re closing your MOOWR licence. At this point, you just need to:
- Pay duty on goods and machinery you’ll keep in India.
- Export, transfer, or destroy the rest before your licence is cancelled.
Your Exit Checklist: Steps to Take Before Debonding
Think of debonding like moving out of a rented house — the better you prepare, the easier it goes.
1. File and Update Returns
- Submit all pending monthly returns (within 10 days of each month’s end).
- Keep records updated and safely backed up for at least five years.
2. Match Stock with Annexure B
- Check that your physical stock matches your Annexure B accounts.
- Reconcile inputs, finished goods, scrap, and machinery with customs documents.
3. Keep Proof of Movements
- · If goods were transferred to another MOOWR unit or exported, keep acknowledgements and proof of receipt ready.
4. Review Bonds and Guarantees
- Check your bond utilisation and make sure no-dues certificates are collected from utilities, landlords, or service providers.
Filing the Application to Exit
To officially surrender your licence, you’ll need to write to your jurisdictional Customs Commissioner.
Your application should include:
- A simple cover letter with your proposed exit date.
- A board resolution authorising the closure.
- Inventory schedules showing whether goods will be exported, destroyed, transferred, or cleared into DTA.
- Annexure B extracts and reconciled returns.
- Draft ex-bond Bills of Entry and duty calculations.
- A request for bond or bank guarantee cancellation.
Customs may do a desk review or even visit your premises. Once all dues are cleared, you’ll receive the licence cancellation order.
Customs Duty at the Time of Debonding
Here’s how duty works when you exit:
1. Inputs, Work-in-Progress, Finished Goods, and Scrap
- Duty = Basic Customs Duty + IGST + Cess.
- Calculated at the rates in force on the date of ex-bond clearance.
2. Goods Cleared “As Is”
- If you haven’t used imported goods and clear them directly to DTA, you’ll pay duty plus interest.
3. Capital Goods (like Machinery or IT Equipment)
- Duty is payable on the original import value at the rate in force on the ex-bond date.
- No depreciation benefit is allowed under MOOWR.
4. Finished Goods Made under Section 65
- You pay duty only on the imported inputs contained in the goods.
- If you export before exit, no duty is charged.
Don’t Forget GST
MOOWR deals with customs duty, but GST rules still apply. Once goods are ex-bonded and sold in India, they become normal taxable supplies under GST.
- Update your GST invoicing, returns, and tax codes from the exit date.
- Keep your MOOWR premises registered as a place of business until all stock is moved.
- Reconcile GST input credits and refunds before you exit.
A Practical Timeline for Debonding
Here’s a simple breakdown to plan your exit:
- 8–10 weeks before exit: Do stock checks, file missing returns, plan how you’ll dispose of inventory, estimate duty.
- 6–8 weeks before exit: Submit your surrender application with reconciliations and board approvals.
- 2–4 weeks before exit: Customs verification, file ex-bond BEs, pay duties, finish exports or transfers, and close pending returns.
- Exit week: Receive licence cancellation, cancel bonds, and archive your records for at least five years.
Common Mistakes to Avoid
- Filing monthly returns late or not at all.
- Stock records not matching with Annexure B.
- Forgetting to pay interest on goods cleared “as is”.
- Assuming depreciation on machinery (not allowed).
- Trying to export stock after licence surrender — it must be done before.
Final Word
Debonding under MOOWR is simply about wrapping things up properly — filing all returns, reconciling stock, paying duties where required, and keeping clean records. If you plan well in advance, it’s a predictable, smooth process with no surprises.
TaxTMI
TaxTMI