Storage of Duty Paid Raw Material

[Rajesh Reddy]

Hi

I am an SSI engaged in the manufacture of corrugated boxes and am registered under central excise. I have since inception not exceeded the SSI exemption limit of ₹ 1.5 crores but have for the purpose of clearing goods meant for export against CT3, registered my proprietory unit under Central Excise. I have also, since inception, not availed any CENVAT Credit. Owing to space constraint at my factory I am from time to time storing raw material (primarily Kraft Paper) at a rented godown. I am however not storing finished/semi-finished goods, nor am I carrying out any manufacturing activity in the said godown. I am of the opinion that so long as I am not availing CENVAT Credit, “duty paid” Raw Material may be stored anywhere and the godown where such material is being stored need not be registered under central excise. I am hoping for the experts to shed some light on whether my stated position is tenable or must i register the godown ? Can you please point me to the relevent Notification(s) and/or Rule(s) that deals with this peculiar situation (if at all).

Regards

Rajesh

[YAGAY and SUN]

You may get the permission for the Commissioner of Central Excise under Rule 4(4).

[MAHESH MAIYA]

Hi,

Refer Rule 8 of Cenvat Credit Rules, 2004 with procedure mentioned in Latest Supplementary Instructions page no. 6.240 of central excise law manual 2015-16.

Thanks

Mahesh Maiya. P

9448680200

AI Summary

Storage of duty-paid raw material: seek Commissioner permission and follow Cenvat Credit procedural guidance for off-site warehouses.
Whether an SSI storing duty paid raw material in a rented godown without availing Cenvat Credit must register that godown; respondents advised obtaining the Commissioner's permission under the excise procedural provision governing storage and following the Cenvat Credit Rules and the Central Excise Law Manual supplementary instructions on procedure.